Alvy legal

Data Processing Agreement

This page explains how Alvy processes loyalty customer data for businesses using the platform.

1. Purpose

This Data Processing Agreement explains how Alvy processes customer, staff, and business data on behalf of businesses that use Alvy.

It is intended to support businesses that need data protection terms for customer phone numbers, emails, loyalty progress, and visit history collected through Alvy.

2. Roles

For customer loyalty data, the business is usually the controller because it decides why customer information is collected and how the loyalty program works.

Alvy is usually the processor because it processes that data to provide the loyalty platform, wallet passes, QR codes, scans, analytics, and related support.

3. Processing Instructions

Alvy will process customer data only to provide the service, follow documented business instructions, comply with law, maintain security, prevent abuse, and support the business account.

4. Data Categories

Data may include customer name, phone number, email address, date of birth where enabled, loyalty progress, rewards, visits, wallet pass identifiers, branch activity, and scan history.

Staff data may include name, phone or username, branch, role, and activity logs.

5. Security Measures

Alvy uses reasonable technical and organisational measures designed to protect data, including access controls, secure infrastructure providers, encrypted connections where available, and operational safeguards.

Businesses must keep owner and staff credentials secure and remove staff access when no longer needed.

6. Subprocessors

Alvy may use subprocessors for hosting, database, authentication, payments, email delivery, analytics, wallet services, and infrastructure.

Examples may include Supabase, Vercel, Stripe, Resend, Apple, and Google where relevant.

7. Data Subject Requests

Alvy will provide reasonable assistance where a business needs to respond to a customer request to access, correct, delete, or export personal data.

8. Deletion and Return

When a business account ends, Alvy may delete, anonymise, or retain data according to the service settings, legal obligations, security requirements, and backup retention periods.

9. Incidents

If Alvy becomes aware of a security incident affecting personal data, we will take reasonable steps to investigate, reduce harm, and notify affected businesses where required.

10. Contact

For data processing questions, contact alvy.co.uk@gmail.com.

These documents are a practical starting point for Alvy. They should be reviewed by a qualified solicitor before you rely on them for every market.