GAP Web Agency Ltd (referred to as “we”, “us” or “our” in this privacy notice) is the data controller and we are responsible for your personal data. We operate the website - https://www.thinkloyalty.co.uk (the "site"). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of our website. By using our website, you agree to the collection and use of information in accordance with this policy.
Full name of legal entity: GAP Web Agency Ltd.
Address: 36 Queens Road, Newbury, Berkshire, RG14 7NE, United Kingdom.
Telephone: 02070 606775
If your information changes, such as a new address or telephone number, please contact us and let us know what has changed, so that the information we maintain is accurate and up to date.
While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal Information that we collect if you contact us by the contact form on our website includes your name, telephone number and email address. You may also decide to include additional personal information in the message field of the contact form ( though this is not a requirement ).
We respect your privacy and do not share your information with anyone.
We do not collect any sensitive data about you. Sensitive data refers to data that contains details about your race or ethnicity, religious beliefs, sexual orientation, political views and information about your health. We do not collect any information about criminal offenses or convictions. We do not carry out any type of automated profiling or decision making.
Under the General Data Protection Data Regulations, we are only legally able to process your personal data if we have a lawful ground in doing so. Our lawful grounds of processing are:
This includes any communication that you may have sent to us either through the contact form on our website, direct email, text, social media messaging, social media posting or any other communication that you sent us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims.
Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions.
Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
This includes data about how you use our website and any of our online services, as well as any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable us to administer our website and business.
Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
This includes data about your use of our website and online services such as your IP address, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.
Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.
Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop and expand them, to grow our business and to plan our marketing strategy.
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since your initial agreement. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Alternatively you can contact us directly to make your requrest.
We may have to share your personal data with the parties set out below:
► Service providers who provide IT and system administration services.
► Professional advisers including lawyers, bankers, auditors and insurers.
► Government bodies that require us to report processing activities.
► Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require that all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
► We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
► If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
► Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have a security measures in place to protect your personal data from being altered, disclosed, used, accidently lost or accessed without authorization. Procedures are in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
Your personal data will only be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by alternative means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they have stopped being customers. In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
In the event that you wish to exercise any of the rights set out above, please email us at
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are unhappy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk). We would be grateful if you would contact us beforehand if you do have a complaint so that we can try to resolve it for you.