The PESEL number or the series and number of the identity document, seems to be incompatible with the GDPR, because to achieve the indicatd goal it will be sufficient to provide, for example, the name and surname, contact details or assignment of a customer number and accumulatd points as part of joining the program. Step three – consider the legal basis for processing One of the most problematic issues when it comes to the correct implementation of solutions relatd to the loyalty program is the choice of the appropriate legal basis for the processing of personal data in accordance with Art.
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The first and most important point of implementation is the rules of the loyalty program.It is in this document that provisions Latest Mailing Database regarding the protection of personal data should also appear. It is primarily a mechanism that allows the participant to become familiar with the rules applicable in the loyalty program, as well as a dose of knowldge about the processing of personal data.
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The regulations should primarily contain information about the purposes and legal grounds for the processing of personal data. Two Book Your List legal constructions of loyalty programs are allowd: a public promise or an agreement. The choice of structure will determine the correct legal basis for the processing of personal data. A more practical form and more often usd in the implementation of a loyalty program is an agreement. This is also confirmd by the position of the judiciary, where the judgments of the courts indicate the so-calld abusive clauses that may appear in the regulations of loyalty programs.