Privacy Policy

Policy Statement
This Privacy Policy applies to World Privilege Plus Ltd. and its wholly-owned UK subsidiary World Privilege Plus Limited ("World Privilege Plus"), and to any member of our World Privilege Plus group. In this Privacy Policy, Personal Data means any information that identifies or could identify a living individual. This Policy sets forth the standards under which World Privilege Plus will treat Personal Data.

Data Control
World Privilege Plus will be the data processor of your Personal Data that is processed by us. World Privilege Plus Ltd. is a company incorporated in the United Kingdom and its UK & US representative is World Privilege Plus Limited. World Privilege Plus Limited is a company incorporated in England with registered office at 373 Bury New Road Prestwich Manchester M25 1AW UK. World Privilege Plus Limited is registered as a data controller with the UK Information Commissioner's Office (ICO) Please see the Contact Us section at the end of this Privacy Policy for information on how to contact World Privilege Plus.

Your Privacy and the World Privilege Plus program
World Privilege Plus ("World Privilege Plus", "we", "us" or "our") is committed to protecting your privacy. This Privacy Policy sets out what data we collect, how we use that data and the choices we offer you, including how to access and update your information.

When you sign up for World Privilege Plus Program, we provide you with a program that aggregates the purchasing power of millions of individuals in order to create special pricing on a wide range of goods and services ("Program"). As a registered user of the Program, you will immediately benefit from the following features:

• Online The ability to make purchases directly with the Merchant through the Program;
• In-Store Rewards: the ability to shop in-store using your own credit or debit card
• Shopping Cards and E-codes: ability to purchase pre-paid shopping cards and instant e-codes; and

As a registered user, you have control over which features of the Program you wish to use. At no time will we trade, sell, or distribute your personal information to any individual, company, vendor or organization, in ways other than as disclosed in this Privacy Policy. If you have any questions or concerns regarding our Privacy Policy, please contact us through one of the methods described in the last section of this Privacy Policy..

Purposes of processing and Lawful basis
We process your Personal Data where the processing is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract with you, and where the processing is necessary for the purposes of the legitimate interests pursued by us, as set out in the table below.

Where we carry out processing based on legitimate interests, we have identified those legitimate interests below.

We may send marketing communications to your individual email address where you have consented to us doing so.

Where we process your Personal Data based on your consent, you have the right to withdraw your consent at any time on the Your Account section or by using the Contact Us page. Any withdrawal of consent by you shall not affect the lawfulness of processing based on your consent before it was withdrawn.

Activity/Purpose	Type of Data	Lawful Basis
Registered User	Personal data either collected from you or received from your organization including name, email, postal code and employee ID	Performance of a contract with the user. Enabling the user to benefit from the reward program
Authenticate and manage user sessions	Authentication data (username, password), session IDs	Necessary for legitimate interests (grant access to platform, manage user activity, prevent fraud)
Process and fulfil transactions	Payment and bank information, transaction history, DOB	Performance of a contract with the user Necessary for legitimate interests (perform e-commerce transactions)
Manage user relationships, including communications and customer service	Personal data including name, email, activity, customer service tickets and browsing history	a.Performance of a contract with the user b.Necessary to comply with a legal obligation c.Necessary for legitimate interests (facilitate user communications and inquiries)
Deliver relevant content including through email marketing and provide recommendations based on profiling	Preferences, reminders, transaction history, site usage activity	Necessary for legitimate interests (provide useful content and experiences to the user)
Analyse usage activity to evaluate program effectiveness and optimize the user experience	Site usage activity	Necessary for legitimate interests (analyse the use of products/services, to keep the website updated and relevant, to develop the business and to inform marketing strategy)
Operate Rewards and Recognition programs	Name, email, transaction history, activity,	a.Performance of a contract b.Necessary for legitimate interests (operate Employers Rewards and Recognition program and the reward program)

Information We Share
Information about you is an important part of our business. We do not sell your information to any third parties. All information disclosing is based on the principle of sharing only the information necessary to fulfil the legitimate business purpose. When shared, data may be transferred and hosted outside the country of origin. We only share your Personal Data with third parties as set out below:

• Aggregated information showing the general use of the Program without any personally identifying information is shared with your organization to evaluate the effectiveness and value of the Program;
•  Information on whether and when you have registered and used the Program may be provided to your organization to minimize redundant or irrelevant communications;
•  Information on spending and savings on the Program may be provided to your organization to be included in total reward statements with other benefits you receive from your organization;
•  RSVPs for private, in-store events, may be provided to participating vendors for admittance to the event;
•  Payment card information will be taken by individual companies when making purchases.
•  Information may be shared with participating merchants in order to fulfil your purchase transaction, including payment information, shipping address and other personal information that may be required to complete such transaction, the member would provide this directly to the merchant.
•  We reserve the right to disclose your Personal Data, to your organization or authorities, as required by law and when it is believed that disclosure is necessary to protect our rights, our clients' interests and/or to comply with a judicial proceeding, court order, or legal process;
•  We will otherwise share your Personal Data with your consent.

Accountability for Onward Transfer
In the event World Privilege Plus discloses Personal Data covered by this Policy to a non-agent third party, it will do so consistent with any notice provided to Data Subjects and any choice they have exercised regarding such disclosure. If World Privilege Plus has knowledge that a third party to which it has disclosed Personal Data covered by this Policy is processing such Personal Data in a way that is contrary to this Policy and/or the Principles, World Privilege Plus will take reasonable steps to prevent or stop such processing. In such case, the third-party is liable for damages unless it is proven that World Privilege Plus is responsible for the event giving rise to the violation.

Profiling
We use profiling in order to enhance your user experience and to present you with discounts that are relevant to you and in line with your browsing history and past purchases. We do not carry out any automated decision making.

If you exercise your right to object to profiling, then we will unsubscribe you from World Privilege Plus and stop processing your Personal Data in accordance with our retention policy. This is because the type of profiling that we carry out is fundamental to the Program and we would not be able to offer the Program without it.

How We Protect the Information
We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, including industry-standard administrative, physical and technical controls. These controls include encryption, third party audits, access controls and security testing.

International Transfers of your Personal Data
Your Personal Data may be transferred outside of your country of origin. We will store your Personal Data on servers located in the United Kingdom

World Privilege Plus complies with the General Data Protection Regulation (GDPR) program in Europe. Framework Principles, including the Supplemental Principles as set forth by the U.S. Department of Commerce (collectively, the "Principles"). World Privilege Plus has certified that it adheres to the Principles with respect to its services and certain Personal Data transferred from the European Union ("EU") to World Privilege Plus.

Your Personal Data may be shared outside of the World Privilege Plus group as stated in the 'Information We Share' section above. Where you purchase from Merchants outside the UK, your Personal Data may be transferred to countries outside of the European Economic Area which do not have equivalent standards of data protection under their legislation and on these occasions.

World Privilege Plus's commitments under the Principles are subject to the jurisdiction and enforcement and investigatory authority of the United Kingdom

Cookies
We do not use cookies on the website however some third parties (e.g., advertisers, tracking utilities) use cookies and Web beacons on their site(s). We do not have access or control over these tracking technologies. We do not share your personally identifiable data with these advertisers.

This Privacy Policy covers our use of cookies on the Program and the private label subdomains delivered by us, only. This Privacy Policy notice does not cover the use of cookies by any third parties.

Email Marketing
We do not send unsolicited marketing emails to individuals without prior consent. We send pre-registration emails at the request of your organization in order to invite you to use the services You may manage the way in which you will receive correspondence, including email reminders, newsletters and Program updates using the "My Account" section of the Program.

Opting Out
All marketing emails sent by us relating to the Program contain instructions on how to unsubscribe from future correspondence. You may opt-out of marketing correspondence relating to the Program by visiting the Contact Us page or by clicking on the unsubscribe link in the marketing email. Users may also access and edit their personal information in the "My Account" section of the website. You can change your communication preferences at any time. You will continue to receive operational emails relating to the Program unless you choose to unsubscribe from the Program.

If you would like your personal information, including email address, to be completely removed from Our database, you should use the Contact Us page. We will respond to your request within thirty (30) business days. Completely removing your personal information from the database will negate your ability to login and use to the Program.

Personal Data and rights for European Economic Area Residents
We will consider any requests made by you under this section in accordance with applicable data protection laws. The rights that apply to European Economic Area Residents are summarized below.

Request Access to Data (Right to information)
You are entitled to request a copy of your Personal Data held by us, as well as a description of how the information is used. A Subject Access Request should be made using the Contact Us page and labelled as 'SAR' or 'Subject Access Request'.

To comply with the Standard Contractual Clauses (model contracts issued by the EU Commission for data transfers outside of the European Economic Area), We may need to notify and obtain authorization from your organization prior to responding to any data subject access request.

Correcting Personal Data (Right to Rectification)
You are entitled to request that any incorrect Personal Data that we hold is corrected. You can also make these changes yourself, through the 'My Account' page.

Deleting Person Data (Right to Erasure)
You are entitled in certain circumstances to request that some or all of your Personal Data is deleted. If you request that all of your Personal Data is deleted we will close your account and you will no longer be able to access World Privilege Plus.

Objecting to or limiting our use of your Personal Data (Right to Object to Processing)
You are entitled in certain circumstances to request that some or all of your Personal Data is deleted. If you request that all of your Personal Data is deleted we will close your account and you will no longer be able to access World Privilege Plus.

Transfer of Your Data (Right to Data Portability)
You are entitled to request a copy of the Personal Data that you provided in machine-readable form.

Right to Know
You are entitled to know about our data collection practices, including:

•  The categories of personal data collected about you
•  The categories of sources your personal data are collected from
•  The categories of third parties your personal data is shared with
•  The business reasons personal data is collected
•  The specific personal data collected about you

Right to Deletion
You are entitled in certain circumstances to request that some or all of your Personal Data is deleted. If you request that all of your Personal Data is deleted we will close your account and you will no longer be able to access Perks at Work.

Right to Know if We Sell Your Personal Data
You are entitled to know if we sell your personal data or disclose it for other valuable consideration, and to whom.
World Privilege Plus does not sell your personal data or disclose it for other valuable consideration under any circumstance.

Right to Opt-Out of the Sale of Your Personal Data
You are entitled to prohibit us from selling your personal data or disclosing it for other valuable consideration. World Privilege Plus does not sell your personal data or disclose it for other valuable consideration under any circumstance.

Right to Access Your Personal Data
You are entitled to prohibit us from selling your personal data or disclosing it for other valuable consideration. World Privilege Plus does not sell your personal data or disclose it for other valuable consideration under any circumstance.

Right to Non-Discrimination
You are entitled to equal service and price, even if you exercise your privacy rights.
To submit a request to exercise your rights under CCPA, please see the Contact Us section, below.

Notification of Changes to the Privacy Policy
This Privacy Policy may be reviewed and amended from time to time. You will be notified of changes to this Privacy Policy by a notice posted on the Program login page. The notice will contain a link, whereby the amended privacy policy can be examined in full. In this way, you will be made aware of policy changes prior to browsing or shopping on the Program. We may e-mail periodic reminders of our notices and conditions, but you should check our website frequently to see recent changes. As always, if you are not amenable to the conditions of revised privacy policy you may opt-out of the Program by the means outlined earlier in the 'Opting Out' section above.

Personal Data - Retention Period
We will store your Personal Data while you remain registered as a user of World Privilege Plus. If you request to be removed we will close your account and your Personal Data will be deleted from our database based on our retention policy. We will retain your Personal Data even after we have closed your account to the extent necessary to comply with our legal obligations and to resolve disputes, and to fulfil your request not to receive further communications from us.

Merchant's Privacy Policies
Many offers on the Program will redirect you to a participating retailer's web site. An interstitial page will be displayed that will inform you that you are being redirected. At this point, you will be on the merchant web site and the merchant's privacy policy will then apply to any information you provide. It is important to read and familiarise yourself with the merchant's privacy policy.

Complaints and Dispute Resolution Process
If you have questions or concerns regarding this Privacy Policy, the Program, or World Privilege Plus's compliance with the Privacy Shield Principles please submit your enquiry through the Contact Us page. You can also contact us at [email protected]

World Privilege Plus will respond to any such inquiries or complaints within 72 hours. services, including instructions for submitting a complaint.

If you are a citizen of the European Economic Area, you should contact the European Union Data Protection Authorities Panel (EU DPA) on [email protected]. The EU DPA will then serve as a liaison to resolve your concerns. Additionally, you have the right to lodge a complaint with the data protection supervisory authority in the UK, the ICO. The ICO website is at https://ico.org.uk/. However, we would request that you contact our Data Protection Officer before making a formal complaint.

World Privilege Plus commits to periodically reviewing and verifying the accuracy of this Privacy Policy and its compliance with the Principles and applicable data privacy legislation), and remedying issues identified.

In Summary
World Privilege Plus is committed to protecting your privacy. We do not sell, trade, give away, or rent personal information to any third parties in ways other than disclosed in this Privacy statement. We use the information collected while you are using the Program in order to make shopping and promotional activities possible and enhance your overall experience of the Program.

Contact Us
We provide several methods for corresponding with us. Please direct your questions or comments to [email protected] or complete the Contact Us form on the website.