This notice explains what personal information we collect when you join and use the Food Lover's Family Loyalty Programme ("the Programme"), how we use it, who we share it with, how long we keep it, and the rights you have. It goes with the Programme's Terms and Conditions, available in the App.
In short: we collect the details you give us when you join, and a record of your shopping when you use your loyalty card or number. We use this to run the Programme and, unless you opt out, to send you offers. We never sell your information and we never share it with other companies for their own marketing. You can request to see, correct or delete your information at any time.
1. Who we are
The Programme is operated by Food Lovers Holdings (Pty) Ltd (registration number 2015/365671/07) ("we", "us", "our"), of 20 London Circle, Brackengate Business Park, Brackenfell, 7560. We are the "responsible party" for your personal information under the Protection of Personal Information Act, 2013 ("POPIA"), which means we decide how and why your information is used, and we are accountable for protecting it.
Participating stores and the service providers who run the Programme's systems process your information only on our behalf and on our instructions.
This notice covers the Programme only: your membership, the loyalty app ("the App"), your loyalty card, and the promotions and competitions that come with membership.
2. What we collect
Information you give us when you join. Your name, your ID number or passport number, and your mobile number. These are required, and without them we cannot register you or operate your membership. Your email address is optional.
Information created when you use your membership. When you scan or give your loyalty card or number: what you bought, when, at which participating store, the price you paid, and the benefits and competition entries applied to the transaction.
Programme records. Your membership status, your competition entries, wins and prizes received, and your communications with Customer Care.
Information we derive from your shopping. Patterns in your shopping with us over time, such as the products and stores you prefer. We use this in aggregated or de-identified form, to understand and improve the Programme. We use it in a form linked to you only to choose which offers to send you.
Technical information from the App. Basic technical details needed to run the App on your device and to send you notifications, such as your device type and a notification token.
3. What we do not collect
We do not link your bank or payment card to your membership.
We do not record your shopping in transactions where you did not use your loyalty card or number.
We do not track your location, and the App does not use GPS.
We do not collect special personal information (such as information about your health, religion, or biometric data).
The Programme is for people 18 and older, and we do not knowingly collect the information of anyone under 18.
4. How we use your information
By joining the Programme and giving us your information, you consent to us using it as described in this notice. POPIA also allows us to use it on the further grounds set out below. We use your personal information:
- to run the Programme. To identify you at the till and in the App, apply member prices, enter you into and run competitions, deliver prizes, and send you service messages about your membership. This is necessary to provide and manage the Programme you joined.
- to meet our legal obligations. The law requires us to keep certain records, for example, records of promotional competitions and winners under the Consumer Protection Act, and tax and accounting records.
- to protect the Programme and our members. To detect and prevent fraud and abuse, enforce the one-membership-per-person rule, and keep our systems secure. We do this based on our legitimate interest in a fair and safe Programme.
- to send you offers, unless you opt out. As a member, we may send you marketing about our own products, services and promotions, and use your shopping history with us to choose which offers to send you, as POPIA allows for our existing customers. See section 9 for your choices.
We use your information only for these purposes. If we ever need to use it for a genuinely new purpose, we will tell you and update this notice.
5. Who we share it with
Your information stays with us and the people who help us run the Programme. We never sell it, and we never share it with anyone for their own marketing.
We share your personal information only with:
- Our service providers, the companies that host, build and operate the Programme's systems and send our communications. They act only on our instructions, only to the extent needed to run the Programme, and are bound by written agreements to protect your information.
- Companies in the Food Lovers Holdings group, for the purposes in section 4.
- Competition sponsors, where a supplier sponsors a competition or promotion, we may share aggregated, de-identified information about it.
- Authorities, where the law requires it.
We do not sell your personal information, and we do not share it with any third party for that third party's own marketing.
6. Where your information is kept
Your information is stored on systems hosted in South Africa. If we ever need to transfer it outside South Africa, we will only do so where the recipient is bound by law or by agreement to protect it to a standard equivalent to POPIA.
7. How we protect it
We use appropriate, generally accepted technical and organisational safeguards to protect your personal information against loss, damage and unauthorised access, and we require the same of our service providers.
If a breach of security ever affects your personal information, we will notify you and the Information Regulator as the law requires.
8. How long we keep it
We keep your personal information for as long as you are a member, and afterwards only for as long as the law requires or allows, for example, competition records must be kept for three years, and financial records for five years.
When information is no longer needed, or upon your request, we delete or de-identify it.
You do not have to wait for us: you can ask us to delete the information that identifies you at any time. See section 11.
9. Marketing
You can opt out of marketing at any time, free of charge, including when you join, or in the App, using the opt-out settings included. If you opt out, we stop sending you relevant offers.
Opting out never affects your member prices or other Programme benefits. It does mean we cannot tell you about offers, so you may not see some of them.
We will still send you service messages about your membership, such as sign-up confirmation, win notifications, security notices and changes to the Programme's terms. These are part of running the Programme and are not marketing.
10. Your rights
You have the right to:
- ask what personal information we hold about you (our PAIA Manual, available on the Food Lover's Market website, explains how to make a formal access request).
- ask us to correct information that is wrong or out of date. You can also update your details yourself in the App.
- ask us to delete your information, as per section 11.
- object to processing based on our legitimate interests, and opt out of marketing at any time.
- complain to the Information Regulator if you believe we have mishandled your information: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; complaints.IR@justice.gov.za; enquiries: inforeg@justice.gov.za.
We will respond to requests within 30 days.
11. Deleting your information
You can ask us to delete your information at any time, through the App or Customer Care. Deletion ends your membership, because we cannot run it without your information.
When you ask us to delete, we will, within 30 days, irretrievably delete the information that identifies you: your name, ID or passport number, mobile number and email address. Your loyalty number and your purchase records are kept only in de-identified form, as an anonymous record that can no longer be linked to you. Records the law requires us to keep are kept for as long as the law requires.
12. Changes to this notice
We may update this notice from time to time, for example, when the Programme or the law changes. The current version, with its latest revision date, is always available in the App.
We will notify members of material changes through the App.
13. Contact us
For anything about your personal information or this notice, contact Customer Care through the support function in the App, or customercare@fvc.co.za.