Privacy Notice

1 Introduction

This Privacy Notice ("Notice") explains how INSPIRING BENEFITS S.L. ("INSPIRING") makes use of the personal information collected about you in connection with the discount club services ("Services") which are made available to you through this platform.

These Services comprise a series of advantages through discounts and offers of goods and services. The Services are offered to you by the organisation by which you are employed or to which you are associated to or a member or client.

INSPIRING is part of the Aon Group. A full list of Aon affiliates/subsidiaries can be found at https://www.aon.com/site/aonworldwide.jsp. Throughout this Notice, INSPIRING may be referred to as "we", "us" or "our".

• Responsible for the data processing: INSPIRING BENEFITS S.L.
• Company address: Calle Velázquez 86-D - 28006 (Madrid)
• CIF: B85936680
• Registration details: Registro Mercantil de Madrid, Tomo 28.105 Folio 125 Sección 8 Hoja M-506370.

2 Collecting Your Personal Information

2.1 The personal information we collect about you may include the following:

• Basic personal details: such as name, surname, email, mobile phone number, address, postcode, city and country;
• Demographic details: such as date of birth, age, gender, photo, information about your family and lifestyle including your hobbies and preferences;
• Unique identifier: such as username, password, employee ID or other similar identification data;
• Payment and purchase information: such as international bank account number ("IBAN") and data related to the transactions you make through the platform;
• Comments, feedback or other information provided to us: such as comments about the Services provided through the platform;
• Marketing and communications preferences: such as preferred communication channels (e.g., email, text message, etc.).

2.2 You are required to provide any personal information we reasonably require (in a form acceptable to us) to meet our obligations in connection with the Services we provide to you, including any legal and regulatory obligations as applicable. Where you fail to provide or delay in providing information, we reasonably require to fulfil these obligations, we may be unable to offer the Services to you and/or we may terminate the Services provided with immediate effect.

2.3 In some instances, we automatically collect certain types of information when you visit our platform and through e-mails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Further information about our use of cookies can be found in our Cookie Policy.

3 Processing Your Personal Information

3.1 We will use the personal information we collect about you in connection with the Services for the following purposes:

• Registration to the Services: In order to use the Services offered through the platform, you are required to fill in a registration form and provide basic personal details including your name, surname, email and postcode. This personal information is used to manage your registration into the platform and make the platform available to you including providing links to other websites and displaying information about other providers. This also allows us to ensure that you can benefit from the Services which have been made available to you through our clients (i.e., the organisation by which you are employed or to which you are associated to or a member or client);


• Communications about the Services by email: Depending on your communications preferences selected during your registration on the platform or under your user profile, we may send you newsletters regarding discounts and offers of goods and services available on the platform that we feel may be of interest to you. You can update your communications preferences at any time under your user profile or by contacting us. We will also always give you the opportunity to unsubscribe on each occasion that you receive a newsletter from us;


• Communications about the Services by text messages: Depending on your communications preferences selected under your user profile, we may contact you by text messages on your mobile phone regarding the current discounts and offers of goods and services available on the platform that we feel may be of interest to you. You can update your communications preferences at any time under your user profile or by contacting us. We will also always give you the opportunity to unsubscribe on each occasion that you receive a text message from us;


• Managing your user profile: Once you have registered on the platform, you have the option to update your user profile. If you update your user profile, we may use this personal information to send you discounts and offers of goods and services available on the platform that we feel may be of interest to you;


• Selection of the Services that we feel may be of interest to you: In order to select and offer discounts and offers of goods and services available on the platform that we feel may be of interest to you, we may use information you provided under your user profile, searches you have done for discounts and offers on the platform, as well as purchases you have made through the platform. This helps us to send you communications by email and/or text messages regarding selected discounts and offers of goods and services available on the platform that we feel may be of interest to you;


• Management of your purchases and money transfer to your piggy bank: In order to manage the purchases you made through the platform including resolving any associated issues, we collect information related to those purchases. In addition, we require you to provide your IBAN to allow us to transfer the money you save to your piggy bank as applicable;


• Inviting friends to the Services: From time to time, you may be able to invite other third-party individuals (such as family members, friends or colleagues) to join the Services by sending them an invitation by email. We only keep the information regarding the number of individuals you have invited as this helps us to evaluate whether you are satisfied with the Services and wish to recommend the Services to others;


• Contest celebration: From time to time we or the organisation which made the Services available to you may organise contests (e.g., Christmas greetings, healthy recipes, photographs, etc.) via the platform. If you sign up for a contest, your basic personal details including your name, surname, email, postcode will be used for your registration to the contest;


• Customer service support: In order to communicate with you and/or respond to your requests, inquiries, comments and concerns/problems in relation to the provision of the Services and canvass your views about the Services;


• Legal and regulatory compliance: In order to fulfil regulatory, legal and compliance obligations including assisting with the prevention, detection and investigation of crime or administrating disputes/complaints in relation to the Services; and


• Process and Services improvement: In order to maintain and improve processes used in running the Services and the platform made available to you including testing and upgrading the systems. We may also anonymise personal information collected through the platform for data analytics purposes to improve the Services generally.

4 Legal Grounds for Processing

We rely on the following legal grounds to collect and use your personal information:

• Performance of the service contract: We will collect and use your personal information where necessary to enable us to take steps to offer you the Services and fulfil our obligations as outlines in Terms of Use of the platform especially for the processing activities set out in sections 3.1(a), (d), (f), (h) and (i) of this Notice.
• Legal and regulatory obligations including preventing and detecting fraud: The collection and use of some aspects of your personal information may be necessary to enable us to meet our legal and regulatory obligations including for preventing and detecting fraud, other financial crime and crime generally especially for the processing activities set out in section 3.1(j) of this Notice.
• Legitimate interests: The collection and use of some aspects of your personal information is necessary to enable us to pursue our legitimate commercial interests, e.g., to operate our business, particularly where we offer other products and services that may be of interest to you or conduct market research to improve our products and services generally especially for the processing activities set out in sections 3.1 (b), (c), (e), (h), (i) and (k) of this Notice. Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.
• Consent: We do not generally rely on your consent to collect and use your personal information for the processing activities set out in section 3 of this Notice.

5 Accuracy of Your Personal Information

We rely on the availability of accurate personal information in order to provide the Services to you and operate our business. You should therefore notify us of any changes to your personal information, particularly changes concerning your basic personal details or IBAN number.

6 Recipients of Your Personal Information

We may from time to time share your personal information with the following categories of recipients where necessary to offer, administer and manage the Services:

• Within the Aon Group: We may share your personal information with other Aon entities, brands, divisions, and subsidiaries for the processing purposes outlined in this Notice;


• Our clients/your organisation: Where necessary to offer, administer and manage the Services provided to you, we may provide information to our clients (i.e., the organisation by which you are employed or to which you are associated to or a member or client and which has offered and made available the Services to you) including: * Your email and username to help your organisation to understand whether you have registered into the platform and/or cancelled your membership to the platform; and * Your name and surname if you have won a contest in order to arrange the delivery of your prize;


• Third-party suppliers: Where we outsource our processing operations to suppliers that process personal information on our behalf. These processing operations shall remain under our control and will be carried out in accordance with our security standards and strict instructions;


• Internal and external auditors: Where necessary for the conduct of company audits or to investigate a complaint or security threat;


• Legal advisers: where necessary to investigate, exercise or defend legal claims or other claims/complaints of a similar nature;


• Public authorities, regulators, government bodies and financial institutions including banks: where necessary for us to comply with our legal and regulatory obligations including assisting with the prevention, detection and investigation of crime; and


• Successors of the business: Where we or the Services are sold to, acquired by or merged with another organisation, in whole or in part. Where personal information is shared in these circumstances it will continue to be used in accordance with this Notice.

7 Overseas Transfers of Your Personal Information

7.1 We operate on a global and worldwide basis and we therefore reserve the right to transfer personal information about you to other countries to be processed for the purposes outlined in the Notice. In particular, we may make such transfers to offer, administer and manage the Services provided to you and improve the efficiency of our business operations. We shall endeavour to ensure that such transfers comply with all applicable data privacy laws and provide appropriate protection for the rights and freedoms conferred to individuals under such laws.

7.2 Where we collect personal information about you in the United Kingdom (the "UK) or the European Economic Area (the "EEA") we may transfer the information to countries outside the UK or EEA for the processing purposes outlined in this Notice. This may include transfers to countries that the European Commission (the "EC") and UK data protection regulator consider to provide adequate data privacy safeguards and to some countries that are not subject to an adequacy decision. Aon has an intra-group data transfer agreement in place which regulates cross-border transfers of your personal information within the Aon Group and which incorporates the UK and EU standard contractual clauses approved by the EC and UK data protection regulator. Where we transfer personal information to third parties located in countries that are not subject to an adequacy decision we shall put in place appropriate safeguards, such as the aforementioned data transfer agreements approved by the EC or UK data protection regulator, as appropriate. Where necessary, we may implement additional technical, organizational or contractual measures to ensure an adequate level of protection for your personal information. Where required, further information concerning these safeguards can be obtained by contacting us.

8 Retention of Your Personal Information

We retain appropriate records of your personal information to operate our business and comply with our legal and regulatory obligations. These records are retained for predefined retention periods that may extend beyond the period for which the Services are made available to you through the platform. In most cases we shall retain your personal information for no longer than five years in accordance with applicable laws. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required.

9 Information Security

The security of your personal information is important to us, and we have implemented appropriate security measures to protect the confidentiality, integrity and availability of the personal information we collect about you and ensure that such information is processed in accordance with applicable data privacy laws.

10 Your Information Rights

You have the following rights under applicable data privacy laws in respect of any personal information we collect and process about you:

a. The right to access your personal information or be provided with a permanent copy of the information being held about you.

b. The right to request the correction of your personal information or in cases where the accuracy of information is disputed, to supplement the information to give notice that you dispute its accuracy.

c. The right to request the erasure of your personal information, particularly where the continued use of the information is no longer necessary.

d. The right to object to the use of your personal information, particularly where you feel there are no longer sufficient legitimate grounds for us to continue processing the information.

e. The right to object to the use of your personal information for direct marketing purposes. See section 11 below for further information.

f. The right to request the restriction of your personal information from further use, e.g., where the accuracy of the information is disputed, and you request that the information not be used until its accuracy is confirmed.

g. The right to request that some aspects of your personal information be provided to you or a third party of your choice in electronic form to enable its reuse.

h. The right to withdraw consent at any time, whenever we have asked for your consent for processing your personal information without affecting the lawfulness of processing based on consent before its withdrawal. See section 4(e) above for further information.

i. The right to complain to the relevant data protection regulator about our processing of your personal information.

10.2 It is important to note, however, that some of the rights described above in section 10.1 can only be exercised in certain circumstances. If we are unable to fulfil a request from you to exercise one of your rights under applicable data privacy laws, we will write to you to explain the reason for refusal. Where required, further information concerning these rights and their application can be obtained by contacting us.

11 Direct Marketing

We will use your personal information to send you direct marketing communications (through email and/or text message) about current discounts and offers of goods and services available on the platform that we feel may be of interest to you as set out under sections 3.1 (b) and (c) of this Notice. If you decide to opt out at any time from receiving such direct marketing communications, please note that we may still send you service-related communications where necessary including updates to this Notice or the Terms of Use.

12 Third party websites

By providing the Services, the platform may redirect you to third-party websites. We shall not be liable to you for any loss or damage arising out or in connection with contents of such websites. You should refer to the privacy notice on these third-party websites for further information about their privacy practices.

13 Complaints

If you wish to make a complaint about the way we use your personal information you should raise this with us by contacting us in the first instance:

INSPIRING BENEFITS S.L.

Calle Velázquez 86-D

28006 Madrid

Spain

Email:[email protected]

However, if you are not satisfied with the way we have handled your complaint you have the right to raise the matter with the UK data protection authority:

Information Commissioner’s Office

Website www.ico.org.uk

14 Changes to this Notice

This Notice is not contractual and we reserve the right to reasonably amend it from time to time to ensure it continues to accurately reflect the way that we collect and use personal information about you. Any updates or changes to this Notice will be made available to you. You should periodically review this Notice to ensure you understand how we collect and use your personal information.

15 Contact Information

If you have any questions about the content of this Notice or the rights conferred to you under the applicable data privacy laws you should contact our Data Protection Officer at the following address:

INSPIRING BENEFITS S.L.

Calle Rosario Pino, 14-16,

28020 Madrid

Spain

Email:[email protected]

This Notice was last updated on 17 January 2024.