Privacy Policy
By participating in the Novelty Card programme in Sri Lanka (the “Programme”), we will collect and use personal data about you and any additional collectors within your account. Companies participate in the Programme by offering Novelty Card discounts (“Discounts”) or a place to redeem them (we call these companies “Novelty Card Partners”). Through participating in the Programme we will learn about what you buy, and you may receive offers and marketing from Novelty Card Partners, the companies whose products they sell or advertise (“Brands”) and other third parties through various Marketing Channels (by this we mean ways of receiving advertising or offers, including email, post, SMS, and our Novelty Card app, and may include other digital channels such as websites, apps, social media and advanced TV).
This privacy policy explains what personal data we collect, the way we use it and why, the circumstances when we may share it, and your choices and rights with respect to your personal data.
This is personal data such as your name, home address, email, and telephone number that you share with us when you create your Novelty Card account.
When you shop with our Novelty Card Partners and use your Novelty Card app, e.g. buy something on an account you’ve linked with Novelty Card, we receive personal data about that transaction. This can include details about the transaction such as what you purchased and where you purchased it.
This is personal data regarding how you interact with the Programme. This includes:
This is personal data that you share with us when you take part in surveys, questionnaires or market research run by us, our Novelty Card Partners, or research partners.
This is the contents of chats, calls and correspondence with our Contact Centre or with our chatbot on the Novelty Card website, and any associated data.
When you enter competitions operated by Novelty Card or our Novelty Card Partners, you may share personal data with us, such as your entry, contact and delivery details.
This is personal data from devices you use to access the internet, including our services such as our websites and apps, received via e.g. cookies and other similar technologies such as pixels. This could be information such as IP addresses, MAC addresses, unique IDs such as advertising IDs, location data, information about your browser, or details contained in URLs used in our communications with you (e.g. offer links in emails).
Cookies are small data files that websites or apps place on your device. To find out more about cookies and similar technologies, please visit our Cookie Policy.
Novelty Card Partners and Brands may share personal data with us (e.g. when you link your account) which they have collected during their relationship with you. This may be information such as how you use their website and apps, your transactions with them, competitions, surveys and marketing you’ve responded to, other loyalty schemes you’ve engaged in, or profiled characteristics attributed to you from your interactions with that company.
This is personal data that we receive or use provided by companies that provide customer information or that is publicly available. These might be companies that help us verify or update your address, or companies that provide us with information on your modelled household profile. This could be received at an individual or an anonymous level such as information based on your address.
Social Media and Digital Advertising – If we market to you using social media or digital advertising platforms (e.g. Google or Facebook), we may use segmentations available on those platforms to help make our marketing more relevant to you.
When personal data has identifying details removed, that information can become anonymous. This can happen if we remove details such as names and addresses, or aggregate personal data into groups and keep only the information about the groups (e.g. a report of shopping behaviour broken down by age), or when we create models from personal data that identify certain characteristics associated with certain traits (e.g. customers likelihood to buy a particular product or category).
Because we can’t identify people within anonymous data, it is treated differently from personal data and is not covered by this policy.
Pseudonymised data is similar but slightly different from anonymous data. Although identifying details such as names and addresses are removed, it is possible to identify them by reference to a ‘key’ held separately. Pseudonymised data may be used to enhance security and privacy by enabling data to be processed at an individual level without requiring identifying details to do so. Pseudonymised data remains personal data and is covered by this policy.
This section explains when we process your personal data, and why we do it. In these use cases, we may use an automated decision-making process which takes into account the types of data listed in each section. For example, when using automated decision-making processes to market to you based on your Novelty Card profile, we might take into account Transaction Information, Account Information and Programme Analytics.
In some cases, you have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects for you or affects you in a similarly significant way.
If you are seeking to exercise this right, please contact us using the details in the “Contact Us” section below.
We will use your personal data to operate the Programme, including to:
| Use | Category of personal data | Legal basis |
| Manage your Novelty Card account, and operate our apps and websites and tailor these to you |
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| Allow you to link your Novelty Card account with your accounts at our Novelty Card Partners |
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| Enable you redeem discounts at Novelty Card Partners |
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| Interact with offers in our app and at Novelty Card Partners |
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| Match data with Novelty Card Partners to aid coordination of marketing of the Programme across Novelty Card and Novelty Card Partner channels |
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| Match data with prospective Novelty Card Partners to assess suitability for the Programme |
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| Personalise your Novelty Card experience based on your location
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| Provide other Programme-related services |
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| Ensure that applicable terms and conditions are observed |
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| Understand how you interact with Novelty Card app and use that information to help create new Novelty Card app features and services |
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| Create and apply anonymous data models from and to your personal data for the uses listed above |
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We will use information about your use of the Programme, our websites and apps to analyse your behaviour for various purposes, including to:
| Use | Category of Personal Data | Legal basis |
| Provide information about you to our Novelty Card Partners and Brands |
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| Improve the Programme, websites and apps |
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| Understand how you use the Programme |
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| Build a profile about you and your profiled characteristics, based on the personal data we have about you from your use of your Novelty Card account, our websites and apps, as well as personal data we receive from Partners, Brands and third parties |
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| Create and apply anonymous data models from and to your personal data for the uses listed above |
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We will use the information available to us to build a profile of you for marketing purposes, including to:
| Use | Category of Personal Data | Legal basis |
| Personalise the marketing and offers you receive from Novelty Card, our Novelty Card Partners and Brands through various marketing channels, including email, post, SMS, our app and Novelty Card Connect, as well as digital channels such as websites, apps, social media and advanced TV |
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| Assess the effectiveness of the marketing activities of Novelty Card, our Novelty Card Partners, Brands and third parties |
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| Personalise marketing and offers based on your location |
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| Create and apply anonymous data models from and to your personal data for the uses listed above
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| Use data matches to identify relevant audiences of Novelty Card collectors and find them on digital channels for the purposes of marketing |
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We may use your personal data when we run competitions of our own or for our Novelty Card Partners and Brands. As an example, this could be your Transaction Information if you needed to make a qualifying purchase to enter, or your Account Information if we needed to contact you to give you your prize.
| Use | Category of Personal Data | Legal basis |
| Competitions |
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Your personal data may be used to conduct surveys and market research. For example, Transaction Information may be used to identify relevant shoppers for a survey on e.g. frozen foods.
| Use | Category of Personal Data | Legal basis |
| Conduct Surveys and Market Research |
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We may use your personal data when we run competitions of our own or for our Novelty Card Partners and Brands. As an example, this could be your Transaction Information if you needed to make a qualifying purchase to enter, or your Account Information if we needed to contact you to give you your prize.
| Use | Category of Personal Data | Legal basis |
| Competitions |
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We combine the personal data we have and analyse it to look for patterns, trends and characteristics that align with a particular outcome – for example, items that are often purchased together, or popular times to redeem Discounts. We use this analysis to create a framework that maps out these patterns, trends and characteristics on an anonymous basis – we call these frameworks “data models” and the process of making them “data modelling”.
Data modelling helps us to analyse the way that groups of people are shopping. For instance, we might look at Transaction Information and see that buyers of ground coffee are starting to buy coffee beans or pods instead – which could be useful information for Novelty Card Partners who sell coffee machines.
We can then apply data models to a personalised data set, to help us tailor the offers that we show Novelty Card app users. For example, sending coffee machine offers to buyers of instant coffee.
In some circumstances we also share personal data with Novelty Card Partners to enable them to create their own models. Please see the “Who will we share your personal data with?” section for further details.
| Use | Category of Personal Data | Legal basis |
| Create data models |
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Provide customer service support
We use your personal data when you use our customer service support, e.g. when you call our contact centre or use our chatbot.
| Use | Category of Personal Data | Legal basis |
| Provide customer service support, including verifying your identity, and for the purposes of training and process improvement |
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To protect your Novelty Card account, to combat fraud and protect our business, we will use your personal data to implement security measures such as Multi-Factor-Authentication, and to investigate and prevent any suspected fraudulent activity across Novelty Card.
| Use | Category of Personal Data | Legal basis |
| Security and fraud |
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We may share your personal data with Novelty Card Partners, for purposes such as:
The types of personal data we share with Novelty Card Partners include:
A list of the current Novelty Card Partners can be found at: https://noveltycard.org/merchant-partners/
We may share your personal data with Brands for the following purposes:
The types of personal data we share with Brands include:
We work with different companies so that they can help us run the Programme, as well as deliver other services you require from us or we think you might be interested in. We share the personal data we have with those suppliers and service providers for the following purposes:
We may also share your personal data with other organisations including:
From time to time we transfer your personal data outside of Sri Lanka for the purposes described in this privacy policy. When we do this, your personal data will continue to be subject to one or more appropriate safeguards set out in the law.
Where we put in place appropriate safeguards to protect personal data we transfer, the safeguards may include securing additional legal agreements to protect your information. You can obtain a copy of these agreements by contacting us using the details in the ‘Contact Us’ section below.
We will keep your information for as long as is necessary for us to fulfil the purposes that we describe in this policy. As a general rule, however, we will keep the personal data we process for the duration of your membership with the Programme.
If you do not earn or redeem Discounts for a period of 12 months we may, in accordance with the Collector Rules, deem you to be inactive and suspend or close your account. Your personal data will be kept and securely stored for a further period of 12 months after you are deemed to be inactive, following which we will ensure that your personal data is no longer retained.
If you would like to request deletion of your personal data, please see the ‘Your choices and rights’ section below.
You have a number of rights under data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal data we process.
Note that some of the choices or changes you make may impact our ability to maintain your account or provide you with discounts and your account may need to be closed. We will notify you if such action is necessary.
You can use the Account section of our website or app to:
To request a copy of the personal data we hold about you, or to correct inaccurate personal data that you cannot change using our website or app, please contact the Privacy Team using the details in the Contact Us section.
To request that we delete the personal data we hold about you, please contact the Privacy Team using the details in the Contact Us section.
You can use the Account section of our website or app to:
To ask that we restrict, or to object to, the processing of your personal data in ways not listed above or to exercise your right to Data Portability, please contact the Privacy Team using the details in the Contact Us section.
Where we rely on consent as the legal basis on which we process your personal data, you may withdraw that consent at any time. To do so, please contact the Privacy Team. Please note that withdrawing your consent does not impact the lawfulness of our prior processing of your personal data based on that consent.
We are Novelwall (Pvt) Limited, a company registered in Sri Lanka [Company reg. no PV 103955]. Our registered office is at 276/ A, The main street, Battaramulla. We are the Data Controller.
If you would like to exercise one of your rights as set out in the “Your choices and rights” section above, or you have a question or a complaint about this policy, or the way your personal data is processed, please contact us by one of the following means:
By email: info@noveltycard.org
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