This is the privacy notice of Defence Discount Service, a trading name of Blue Light Card Ltd. In this document we refer to us as "Blue Light Card" "we, "our", "us". We are registered under company number 06581540 in the UK. Our registered office is at Charnwood Edge Business Park, Syston Road, Leicester, LE7 4UZ.

Blue Light Card respects your privacy and is committed to protecting your personal data.

This privacy notice aims to give you information on how we collect and process your personal data when you use our websites or mobile applications (together sites), use our services or otherwise correspond or deal with us.

Our sites are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice, together with any other notice that we may provide you on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This notice supplements other notices but is not intended to override them.

Blue Light Card Ltd is the controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO, using the contact details below:

Blue Light Card Ltd
Charnwood Edge Business Park, Syston Road, Leicester, LE7 4UZ
[email protected]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We keep our privacy notice under regular review. This notice was last updated on 8 December 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our sites, we encourage you to read the privacy statements of every website you visit.

Information we collect

We may process the following types of personal data about you:

• Full name, email address, position, staff number/service number, employer
• Gender
• Financial data including your bank account and payment card details
• Email address and mobile number
• County
• Address
• Copy of ID/service documents or other proof of employment
• Date of Birth
• Transaction data including details of payments to and from you and other details of products and services you have purchased from us
• Technical data including your IP address, internet service provider, geographical location, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, screen resolution and platform, and other technology on the devices you use to access our sites
• Username and password
• Member card numbers and member ID
• Voucher codes and QR codes allocated to you
• Preferences (including marketing preferences and details of your interests, company ‘follows’ and company ‘hides’)
• Survey or feedback responses
• Usage data about how you use our sites, products and services
• Personalised redemption data relating to sales and savings
• Information, dates and times you have used our sites to login, request passwords, register on our sites
• Information relating to offers you view and click including time/date, company, offer, newsletter offer used.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you, including through:

• Direct interactions, when you sign up to our service, create an account, enter a competition, promotion or survey, give us feedback, fill in forms, enter into a contract with us or correspond with us by post, phone, email or otherwise.
• When you use our sites we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data using cookies, server logs and other similar technologies. Please see our cookies policy for details.
• We will receive personal data about you from various third parties and public sources including affiliate networks, retailers featured on our site, third party platform providers (such as Eden Red for gift cards), analytics providers, advertising networks and search information providers.

You may choose to sign into our app, following initial sign in, using a fingerprint or facial recognition. That information is collected and processed at a device level and Blue Light Card will not receive or process that personal data.

Affiliate Networks

Blue Light Card works with a number of affiliate networks to provide our service to you. Blue Light Card may be a joint controller with those affiliate networks under the data protection legislation in order to track any commission payable by advertisers to us. In respect of the processing for which Blue Light Card and the relevant affiliate network are joint controllers, you may exercise your rights against Blue Light Card, as set out below, or the relevant affiliate network, as set out in the privacy policy for those networks linked to below:

• Awin: Privacy Policy of the Awin Group | Awin
• Affiliate Future: Affiliate Future privacy statement
• Affiliate Gateway: Privacy | The Affiliate Gateway
• Commission Junction: Privacy Policy Services Uk (cj.com)
• Tradedoubler: Privacy Policy | Tradedoubler – Connect and Grow
• Webgains: Webgains Personal Data Protection Policy | WEBGAINS
• Rakuten: Privacy Policy | Rakuten
• Impact Radius: Privacy Policy | Impact
• Partnerize: Privacy Policy - Partnerize

Specific uses of information you provide to us

We have set out below a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Table showing how we process personal data

Purpose/ Activity	Lawful basis for processing
To register you as a member	Performance of a contract with you
To provide our service to you	Performance of a contract with you
To check your identity and age to ensure that you are eligible for our service	Performance of a contract with you
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy notice Asking you to leave a review or take a survey Arranging for refunds where applicable (d) sending other service communications to you.	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw (or a ticket draw on our Blue Light Tickets site), competition or complete a survey	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To invite you to partake in relevant prize draws, competitions or complete a survey	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) Consent
To consider your usage of our service to determine whether you are eligible to take part in our member panel, Blue Light Card Voices, and to invite you to that panel.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To provide you with a secure service or sites	Necessary for our legitimate interests (to ensure that your data remains secure) Necessary to comply with a legal obligation
To personalise your service. including to deliver relevant sites content, marketing communications and advertisements to you	Consent Necessary for our legitimate interests (to ensure that you are provided with relevant communications and content)
To measure or understand the effectiveness of the marketing communications and advertising we serve to you, including placement of pay-per-click advertising	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our sites, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Necessary for our legitimate interests (to develop our products/services and grow our business)
To prevent fraud	Necessary for our legitimate interests (to ensure that our services are used in the way they are intended) Compliance with a legal obligation
To place orders with suppliers and manage payments to suppliers	Performance of a contract with you Necessary for our legitimate interests (to procure goods and services for our business)
To calculate commission payable by our partners	Consent (where required) Legitimate interests (to determine when commission is payable by our partners)
To deal with member queries, complaints and requests	Performance of a contract with you Compliance with a legal obligation Legitimate interests (to provide a good service to members)
Sending marketing communications via email, SMS, push notification and in-account notifications	Consent Legitimate Interests (to enhance our business)
To integrate with social media via ‘like’ buttons	Consent (to allow you to integrate with your social media profiles)
To source and manage relationship with partners	Performance of a contract with you Legitimate Interests (to enhance our business)
To source and manage relationships with businesses that have employees that are eligible to use our service	Performance of a contract with you Legitimate Interests (to enhance our business)
To comply with our legal obligations	Compliance with a legal obligation
To audit our services and sites	Compliance with a legal obligation Legitimate Interests (to ensure that we are managing our service and sites in a compliant way)

Marketing

We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your personal data to form a view on what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have consented to do so.

You can ask us to stop sending you marketing messages at any time by logging into your account on our sites and checking or unchecking relevant boxes to adjust your marketing preferences, or by contacting us at any time.

Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Our sites use cookies. For more information about the cookies we use, please see our cookies policy.

Social Media

Our sites use Facebook to build audiences for retargeting and lookalike advertising campaigns on Facebook. You can also ‘like’ our sites and our service on Facebook via a button on our site. Blue Light Card is a joint controller with Facebook Ireland under the data protection legislation for any personal data processed for those purposes.

Blue Light Card and Facebook Ireland have entered into an addendum, available here: Facebook to determine the respective responsibilities for compliance with the obligations under the GDPR with regard to the joint processing.

Further information about how Facebook Ireland processes personal data, including the legal basis Facebook Ireland relies on and the ways to exercise data subject rights against Facebook Ireland, can be found in Facebook Ireland's Data Policy at https://www.facebook.com/about/privacy

Disclosure and sharing of your information

In the event that you have are required to collect tickets from a box office on our Blue Light Tickets website (bluelighttickets.co.uk), we may be required to share your personal data with the event organiser or venue to enable you to do so.

We may share your information with service providers acting as data processors on our behalf, including providers of the following services:

• IT hosting or support
• CRM and systems
• Payment processing (Stripe)
• customer surveys
• live chat
• analytics and tracking services (including to track use of our codes, sales made and commission payable)
• fraud prevention and
• market research services.

We may share information with our professional advisors (including our lawyers, third party auditors and insurers).

We may disclose personal data following a request from the police.

We may disclose personal data to social media companies (such as Facebook) for the purposes for providing you with relevant advertisements and enabling you to use the ‘like’ buttons on our website.

Other payment methods are available on our site including PayPal, Apple Pay and Google Pay. Those payment providers will process your personal data in accordance with their own privacy policies available on their sites.

We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We will disclose information if we have a legal obligation to do so.

Data processing outside the UK

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• where countries have been deemed to provide an adequate level of protection for personal data
• we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us at [email protected] or by submitting a support ticket via our website or mobile apps or, as a non-logged in user, via the contact form on our main homepage.

If you wish to exercise your right to access your personal data, we have also provided a button on the My Account section on our website to enable you to easily request your personal data.

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Access to your personal data

At any time you may request a copy of your personal data that we hold about you and check that we are lawfully processing it or request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Erasure of your personal data

You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objection to processing

You have the right to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes. You also have the right to ask us not to process your personal data where it is processed on the basis of legitimate interests (see the table under ‘Specific uses of information you provide to us’ above) provided that there are no compelling reasons for that processing.

Request restriction of processing of your personal data

You have the right to ask us to suspend the processing of your personal data if you want us to establish the data's accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party

You have the right to ask us provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time

Where we are relying on consent to process your personal data you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Other matters

Use of our site and services by children

• We do not sell products or provide services for purchase by children, nor do we market to children.
• You are required to be 16 years or older, in order to use our website and apps.
• You are required to provide a date of birth to ensure the products and services we are advertising are suitable.

Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.