Data processing agreement
Last updated: 11 October 2026
This agreement is part of the terms of use and applies between the shop (“controller”) and Loyi, [company name or your full name], [street, postcode, city], Belgium, [company number] (“processor”). It covers the personal data Loyi processes for the shop's loyalty programme, as required by article 28 of the GDPR.
1. Subject, duration, nature and purpose
Loyi runs the shop's digital loyalty programme: it stores client cards, records stamps and redeemed rewards, shows the shop's dashboard, client list and insights, and shows the shop's follow-up messages on its clients' cards. The agreement lasts as long as the shop has a Loyi account.
2. Data and people concerned
- People: the shop's clients who collect stamps.
- Data: pseudonymous client IDs, cards, stamps, rewards earned and used, and the date and time of each tap. Loyi does not process names, email addresses or phone numbers of clients for the shop. No special categories of data.
3. Instructions
Loyi processes this data only to provide the service as described in the terms and in the app, and on the shop's documented instructions, which are its settings and actions in Loyi. If Loyi believes an instruction breaks the law, it tells the shop. Loyi does not use the data for its own purposes, except to keep the service secure and to prevent fraud, as explained in the privacy policy.
4. Confidentiality and security
Only people who need it to run Loyi have access, and they are bound to confidentiality. Loyi takes appropriate technical and organisational measures (article 32), including: pseudonymous client IDs, encrypted connections, database rules that check every write, access limited to each shop's own data, data stored in the EU (Belgium), and automatic deletion of stamp and reward history after 2 years.
5. Sub-processors
The shop gives general permission for these sub-processors:
- Google Ireland Ltd (Firebase): database, hosting and sign-in. Database in Belgium (europe-west1); sign-in data can be processed in the United States under the EU–US Data Privacy Framework or the European Commission's standard contractual clauses.
- Cloudflare, Inc.: Loyi's small server, which checks taps on secure Loyi tags (the tag's one-time code and the client's anonymous ID). It runs on Cloudflare's network, under Cloudflare's data processing addendum with the European Commission's standard contractual clauses.
Loyi informs shops by email at least 30 days before adding or replacing a sub-processor. A shop that objects can end its subscription before the change. Loyi binds each sub-processor to the same data protection obligations.
6. Help with clients' rights and obligations
Clients can see, download and delete their own data in Loyi themselves. Where needed, Loyi helps the shop answer requests from clients and meet its obligations on security, data breaches and impact assessments (articles 32 to 36), taking into account the nature of the processing.
7. Data breaches
Loyi informs the shop without undue delay, and where possible within 48 hours, after becoming aware of a personal data breach affecting its clients' data, with the information the shop needs to notify the Data Protection Authority and, if required, its clients.
8. End of the agreement
When the shop deletes its account, Loyi deletes the data of its loyalty programme straight away; the shop can download a copy beforehand under Account & privacy → Download my data. Backups kept by the hosting provider are overwritten within its normal cycle.
9. Audits
Loyi gives the shop the information it needs to show compliance with this agreement and allows reasonable audits, announced in writing at least 30 days in advance, at the shop's own cost and at most once a year unless a breach requires it.
10. Liability and law
The liability rules and the applicable law of the terms of use apply. If this agreement and the terms differ on data protection, this agreement prevails.