Field guide

Keep signup, consent and private passes separate

A practical privacy checklist for public enrollment and staff/customer records.

Practical guidance · examples to adapt · not legal or financial advice

1. Public is not private

Your business page lists active programs and location/contact terms. It must not list customer balances or private pass codes. Customers use their own private identity for progress.

2. Explain the records

Qualification can record customer identity, eligible paid purchase amounts, receipts/reference, program progress, points/stamp events, referrals and redemption history. Collect only what your operation needs.

3. Keep marketing optional

Program enrollment is not promotional consent. The separate marketing choice is optional and unchecked. App email delivery is currently off; do not assume signup sends a marketing email.

4. Restrict staff access

Assign checkout staff to appropriate locations. Do not share owner logins. Authorized owners can export customer records; reasoned corrections leave a record.

5. Handle requests carefully

Direct reward questions to the merchant and account/data questions to the appropriate contact. Verify identity before disclosure or deletion; retention duties and other people’s rights may limit deletion. Do not email private passes or payment secrets. Review the draft Privacy and Cookies policies for your markets.

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