Privacy Policy

1. Introduction

1.1 Our Commitment to Privacy

Privi is committed to protecting your privacy and handling your personal information responsibly, transparently and securely.

This Privacy Policy explains what personal information we collect, how we use it, why we collect it, how we protect it and the rights you have regarding your personal information.

We believe that privacy should be straightforward. We only collect the information necessary to provide and improve the Privi Membership service.

1.2 Scope of this Policy

This Privacy Policy applies to all personal information collected through:

• the Privi website;
• the Privi mobile application;
• Membership registration;
• customer support communications;
• other services operated by Privi.

It should be read alongside the Privi Terms & Conditions and any other policies published by Privi.

1.3 Data Controller

For the purposes of applicable data protection legislation, Privi is the Data Controller responsible for deciding how your personal information is collected and used.

The registered company details will be published on the Privi website once the business is incorporated.

2. Information We Collect

2.1 Information You Provide

When creating an account or using Privi, you may provide information including:

• your name;
• your email address;
• an encrypted password;
• payment-related information required to process your Membership (processed through authorised payment providers);
• communications you send to our support team;
• any information you choose to provide when contacting us.

2.2 Membership Information

To operate your Membership, we maintain information including:

• Membership status;
• subscription type;
• payment status;
• renewal dates;
• account creation date;
• account preferences;
• favourite Businesses or Offers where this feature is available;
• redemption history where necessary to operate the service;
• referral activity, where you choose to participate in the referral programme.

2.3 Device Information

When you access Privi, certain technical information may be collected automatically, including:

• device type;
• operating system;
• application version;
• browser type where applicable;
• internet protocol (IP) address;
• device identifiers where reasonably necessary;
• security and diagnostic information.

This information helps us maintain security, diagnose technical issues and improve the reliability of the Platform.

2.4 Location Information

If you choose to grant permission, Privi may access your approximate device location to display nearby Businesses and Offers.

Location services are optional.

You may disable location permissions at any time through your device settings, although doing so may reduce the functionality of location-based features.

Privi does not continuously track your location.

2.5 Information We Do Not Intentionally Collect

Privi is designed to minimise the personal information we collect.

Unless required for a specific feature or legal obligation, we do not intentionally collect:

• date of birth;
• postal address;
• telephone number;
• sensitive personal information;
• biometric information;
• precise location history.

3. How We Use Your Information

We use your personal information only where there is a legitimate reason to do so.

This includes:

• creating and managing your Membership;
• processing subscription payments;
• providing access to Member features;
• displaying relevant Businesses and Offers;
• verifying Membership status where required;
• providing customer support;
• maintaining account security;
• detecting and preventing fraud;
• improving the Platform;
• complying with legal obligations.

We do not collect personal information for purposes unrelated to the operation of the Membership service.

4. Legal Basis for Processing

Depending on the circumstances, Privi processes personal information because:

• it is necessary to perform the Membership contract;
• it is necessary to comply with legal obligations;
• it is necessary for Privi's legitimate business interests where those interests do not override your rights;
• you have provided consent where consent is required.

Where processing is based upon consent, you may withdraw that consent at any time without affecting processing carried out before consent was withdrawn.

5. Payment Information

Privi does not store your full payment card details.

Payments are processed securely by authorised third-party payment providers.

Those providers are responsible for securely handling payment information in accordance with applicable payment industry standards and data protection legislation.

6. Sharing Your Information

6.1 Participating Businesses

Privi does not provide participating Businesses with your personal information unless it is reasonably necessary to validate your Membership or comply with legal obligations.

Businesses do not receive your payment information.

6.2 Service Providers

Privi may share limited personal information with trusted third-party providers that assist in operating the Membership service.

Examples include:

• payment processing;
• cloud hosting;
• customer support systems;
• email delivery services;
• analytics services;
• security monitoring.

These providers may only process personal information on Privi's behalf and only for the purposes authorised by Privi.

6.3 Legal Requirements

Privi may disclose personal information where required to:

• comply with applicable law;
• respond to lawful requests from public authorities;
• establish, exercise or defend legal claims;
• protect the rights, safety or security of Members, Businesses or Privi.

7. Marketing Communications

Privi may send service-related communications that are necessary for the operation of your Membership.

Examples include:

• payment confirmations;
• renewal reminders;
• important account notices;
• security alerts;
• updates affecting your Membership.

Where you choose to receive marketing communications, you may unsubscribe at any time using the methods provided in those communications.

Choosing not to receive marketing messages will not affect essential service communications.

If you join Privi's pre-launch waitlist before Membership sign-up is open, we collect your email address solely to notify you once sign-up becomes available. You may ask us to remove your email from the waitlist at any time by contacting us.

8. Data Security

Privi takes appropriate technical and organisational measures to protect personal information.

These measures include, where appropriate:

• encrypted passwords;
• secure data storage;
• restricted administrative access;
• encrypted data transmission;
• system monitoring;
• regular security updates;
• access controls based on business need.

Although Privi takes reasonable steps to safeguard information, no online system can guarantee absolute security.

9. Data Retention

Privi retains personal information only for as long as reasonably necessary to:

• provide the Membership service;
• comply with legal obligations;
• resolve disputes;
• enforce legal agreements;
• protect against fraud.

When information is no longer required, it will be securely deleted or anonymised where appropriate.

Further information regarding retention periods is available in Section 16 (Data Retention) below.

10. Your Rights

Subject to applicable law, you have the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request deletion of personal information where applicable;
• request restriction of processing in certain circumstances;
• object to certain processing activities;
• request transfer of your personal information where applicable;
• withdraw consent where processing relies upon consent;
• lodge a complaint with the relevant supervisory authority.

Privi will respond to valid requests within the timescales required by applicable law.

11. Cookies and Similar Technologies

Privi uses cookies and similar technologies to support the operation of the website and improve the user experience.

Further information is provided in the Privi Cookie Policy.

Where required by law, you will be given the opportunity to manage your cookie preferences.

12. International Data Transfers

Where personal information is transferred outside the United Kingdom, Privi will ensure that appropriate safeguards are in place as required by applicable data protection legislation.

13. Children's Privacy

Privi Membership is intended for individuals aged 18 years or over.

Privi does not knowingly collect personal information from children.

If we become aware that personal information relating to a child has been collected without appropriate authority, reasonable steps will be taken to delete that information.

14. Changes to this Privacy Policy

Privi may update this Privacy Policy from time to time to reflect:

• changes in legislation;
• changes to the Membership service;
• improvements to our systems;
• changes to the way personal information is processed.

The most recent version will always be published on the Privi website.

Where changes materially affect your privacy rights, reasonable notice will be provided.

15. Your Right to Complain

If you believe that your personal information has not been handled in accordance with applicable data protection legislation, you have the right to make a complaint to the relevant supervisory authority (the Information Commissioner's Office in the UK).

16. Data Retention

This section sets out Privi's Data Retention Policy in full — how Privi retains, manages and securely disposes of information collected during the operation of the Membership service. Privi is committed to retaining personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, comply with legal obligations and protect the legitimate interests of Members, participating Businesses and Privi.

16.1 Scope

This section applies to all personal information and business information processed by Privi in connection with:

• Membership accounts;
• Business Partner accounts;
• the Privi website;
• the Privi mobile application;
• customer support;
• payment administration;
• operational records.

16.2 Retention Principles

Privi follows the following principles when retaining information:

• information will only be retained where there is a legitimate business or legal reason to do so;
• information will not be retained indefinitely without justification;
• information will be securely deleted or anonymised when no longer required;
• access to retained information will be restricted to authorised personnel;
• retention periods will be reviewed periodically to ensure continued compliance with applicable legislation.

16.3 Types of Information Retained

Depending upon the services used, Privi may retain information including:

• Member account information;
• Business Partner information;
• Membership records;
• subscription records;
• referral programme records;
• payment records;
• customer support communications;
• technical logs;
• security records;
• fraud prevention records;
• website administration records;
• operational audit records.

Privi does not retain information that is unnecessary for the operation of the Membership service.

16.4 Membership Information

Member account information may be retained for as long as reasonably necessary to:

• provide Membership services;
• administer subscriptions;
• manage Member accounts;
• comply with legal obligations;
• investigate disputes;
• prevent fraud.

Where a Membership ends, certain records may continue to be retained where legally or operationally necessary.

16.5 Payment Information

Privi does not retain full payment card details.

Payment providers retain payment information in accordance with their own legal and regulatory obligations.

Privi may retain limited payment-related records necessary to:

• confirm payments;
• administer subscriptions;
• process refunds;
• maintain financial records;
• comply with accounting and taxation requirements.

16.6 Business Partner Information

Business information may be retained for as long as reasonably necessary to:

• administer Business Partner relationships;
• maintain operational records;
• investigate complaints;
• comply with legal obligations;
• resolve disputes.

Where a Business leaves the Platform, certain historical records may continue to be retained where appropriate.

16.7 Customer Support Records

Communications with Members and Businesses may be retained for purposes including:

• responding to enquiries;
• investigating complaints;
• improving customer service;
• protecting Privi against legal claims;
• maintaining operational records.

Support records will not be retained longer than reasonably necessary.

16.8 Technical and Security Information

Privi may retain technical and security records relating to:

• system access;
• login activity;
• security monitoring;
• fraud prevention;
• software errors;
• operational diagnostics.

Such records assist Privi in maintaining the security, integrity and reliability of the Platform.

16.9 Fraud Prevention

Where fraud or misuse is suspected, Privi may retain relevant information for longer where reasonably necessary to:

• investigate suspected misconduct;
• prevent repeated abuse;
• comply with legal obligations;
• establish, exercise or defend legal claims.

Retention in these circumstances will be limited to what is reasonably necessary.

16.10 Legal and Regulatory Requirements

Certain records may need to be retained in order to comply with:

• taxation legislation;
• accounting obligations;
• consumer protection legislation;
• data protection legislation;
• court orders;
• lawful requests from regulatory or public authorities.

Where legal obligations require longer retention periods, those obligations take precedence over standard operational retention periods.

16.11 Deletion of Information

When information is no longer required, Privi will take reasonable steps to ensure that it is:

• securely deleted;
• permanently erased where appropriate;
• anonymised where continued statistical use is beneficial and lawful.

Deletion methods will be appropriate to the nature of the information being removed.

16.12 Member Requests

Members may request the deletion of their personal information where applicable under data protection legislation.

Privi will consider each request in accordance with:

• applicable law;
• this Privacy Policy;
• legitimate business requirements;
• legal obligations requiring continued retention.

Where information cannot be deleted immediately, Privi will explain the reasons where appropriate.

16.13 Security of Retained Information

Information retained by Privi is protected through appropriate technical and organisational measures.

These may include:

• restricted administrative access;
• encrypted storage where appropriate;
• secure backup procedures;
• authentication controls;
• system monitoring;
• security updates.

Access to retained information is limited to authorised individuals who require access for legitimate business purposes.

16.14 Review of Retention Practices

Privi will periodically review its retention practices to ensure they remain:

• appropriate;
• proportionate;
• legally compliant;
• operationally necessary.

Where improvements are identified, this section may be updated accordingly.

Privacy First

Privi is built on a simple principle:

We collect only the information necessary to provide the Membership service. We do not collect personal information simply because we can. Protecting your privacy is fundamental to the way Privi operates.