1. Introduction

DALPS ("we," "our," or "us") operates a universal loyalty platform. This policy explains how we collect, use, and protect your personal information when you use the DALPS card, app, and services.

2. Information We Collect

Personal Information: Name, email address, phone number when you create an account.

Transaction Data: We collect detailed information about your purchases at participating retailers, including:

• Date, time, and location of purchase.
• Product-level data (items purchased, quantities, prices paid).
• Total transaction value.

Technical Data: Device information, IP address, and usage data from our app and website.

Consent Data: Your preferences for personalized advertising and content, advertising and content measurement, audience research and services development, and storage and/or access information on a device.

3. How We Use Your Information

We use your information to:

• Provide and manage your loyalty rewards.
• Aggregate and anonymize your transaction data for commercial purposes. This is core to our business model. This anonymized, aggregated data is sold to third parties such as:
  • AI and Machine Learning Companies for model training.
  • Consumer Packaged Goods (CPG) Brands for market research.
  • Financial and Economic Analysis Firms.
• Personalize your experience and communicate with you.

4. Legal Basis for Processing (GDPR)

We process your data based on:

• Performance of a Contract: To provide you with the loyalty services.
• Legitimate Interest: For the aggregation, anonymization, and sale of commercial insights, which funds the rewards you earn.
• Consent: For specific marketing communications, where required by law.

5. Your Rights

You have the right to access, correct, or delete your personal data. You may object to the processing of your personal data for direct marketing. To exercise these rights, contact us at privacy@dalps.org.

6. Data Sharing

We do not sell your personal information (e.g., your name and what you bought). We do sell insights derived from aggregated and fully anonymized data, which cannot be traced back to you.