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Privacy Policy

Last Updated: 31 July 2026

 

1. Introduction

Sweete ("Sweete", "we", "our" or "us") is committed to protecting the privacy and security of personal data. We recognise the importance of handling personal information responsibly and transparently and are committed to ensuring that all personal data is processed fairly, lawfully and securely.
This Privacy Policy explains how Sweete collects, uses, stores, shares and protects personal data when providing our services and when you visit our website.
We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Data Protection Act 2018 and any other applicable data protection legislation.
By using our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy.


2. Who We Are
Sweete is an Irish provider of loyalty programmes, rewards platforms, promotional campaigns, competitions, digital vouchers, gift cards and related marketing services. As part of providing these services, we are entrusted with processing personal data on behalf of our clients and are committed to maintaining the highest standards of privacy and information security.

3. Data Controller and Data Processor

Sweete generally acts as a Data Processor on behalf of its clients when delivering loyalty programmes, promotional campaigns, competitions, rewards platforms and related services.

Where we act as a Data Processor, we process personal data solely on the documented instructions of our clients and only for the purposes agreed with them.

 

In certain circumstances, Sweete may act as a Data Controller, for example when processing personal data relating to:

  • enquiries submitted through our website;

  • supplier relationships;

  • recruitment activities;

  • our own business administration; or

  • any other activity where Sweete determines the purposes and means of processing.


4. Personal Data We Process

The categories of personal data processed by Sweete vary depending on the service being provided and the requirements of our clients.

Sweete may process personal data when administering:

  • Loyalty and rewards programmes;

  • Promotional campaigns and competitions;

  • Digital vouchers and gift cards;

  • Reporting portals and programme analytics;

  • Prize fulfilment and winner verification; and

  • Customer support enquiries.

Where Sweete acts as a Data Processor, the categories of personal data processed are determined by our client and are limited to what is necessary to provide the agreed services.

5. How We Use Personal Data
Depending on the services being provided, personal data may be processed for purposes including:

  • administering loyalty and reward programmes;

  • managing promotional campaigns and competitions;

  • validating participant eligibility;

  • allocating and delivering rewards, vouchers and prizes;

  • communicating with participants where necessary;

  • providing reporting and analytics to clients;

  • responding to customer support enquiries;

  • maintaining and securing our systems;

  • complying with legal and regulatory obligations; and

  • improving our services and website.

We will only process personal data where there is a lawful basis for doing so.

6. Lawful Bases for Processing
Where Sweete acts as a Data Controller, we process personal data on one or more of the following lawful bases under Article 6 of the GDPR:

  • performance of a contract;

  • compliance with a legal obligation;

  • our legitimate interests, provided those interests are not overridden by the rights and freedoms of the individual;

  • consent, where required by law; or

  • any other lawful basis permitted under applicable data protection legislation.

Where Sweete acts as a Data Processor, we process personal data solely on behalf of and under the documented instructions of our client, who is responsible for determining the appropriate lawful basis for the processing.

7. Sharing Personal Data
Sweete does not sell personal data.
We may share personal data where necessary with:

  • our clients;

  • carefully selected service providers who assist us in delivering our services;

  • prize fulfilment partners where applicable;

  • professional advisers;

  • regulatory authorities where required by law; and

  • other third parties where legally permitted or required.

All third-party processors engaged by Sweete are required to process personal data securely and only in accordance with our instructions and applicable data protection legislation.

8. Third-Party Service Providers
Sweete uses carefully selected third-party service providers to support the delivery of our services.
Our primary hosting provider is Amazon Web Services (AWS), with infrastructure located in Ireland (EU-West-1).
Where third-party providers process personal data on our behalf, appropriate contractual safeguards are in place to ensure that personal data is protected in accordance with the GDPR.

 

9. International Transfers
As part of our standard service delivery, Sweete hosts personal data within the European Economic Area (EEA). Our primary hosting environment is Amazon Web Services (AWS) located in Ireland (EU-West-1).
Sweete does not intentionally transfer personal data outside the EEA as part of its standard services.
Should an international transfer become necessary in the future, we will ensure that appropriate safeguards are implemented in accordance with Chapter V of the GDPR.

10. Data Retention
Sweete retains personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and contractual obligations. For promotional campaigns and competitions, participant data is generally retained for the duration of the campaign and for a short period afterwards to facilitate winner selection, validation, reporting and campaign administration.

Unless a longer retention period is required by law or agreed with our client, campaign participant data is securely deleted or anonymised approximately 14 days after the relevant processing activities have been completed.

11. Security
Sweete takes the security of personal data seriously. We maintain appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
These measures include, where appropriate:

  • secure hosting infrastructure;

  • access controls based on business need;

  • password protection and user authentication;

  • encryption of data in transit where appropriate;

  • regular monitoring of systems; and

  • internal policies governing the secure handling of personal data.

While no method of transmission or storage can be guaranteed to be completely secure, Sweete continually reviews and updates its security practices to help safeguard personal data.

12. Your Rights
Where Sweete acts as a Data Controller, individuals have the following rights under the GDPR, subject to certain legal limitations:

  • the right of access;

  • the right to rectification;

  • the right to erasure;

  • the right to restrict processing;

  • the right to object to processing;

  • the right to data portability;

  • the right to withdraw consent where processing is based on consent; and

  • rights relating to automated decision-making, where applicable.

Where Sweete acts solely as a Data Processor on behalf of one of our clients, requests relating to these rights should generally be directed to the relevant client, who is the Data Controller. We will assist our clients in responding to such requests where required.


13. Exercising Your Rights
If you wish to exercise any of your data protection rights or have any questions about how your personal data is processed, please contact us at: info@sweete.ie. We will respond to requests within the timeframes required by applicable data protection legislation.

 

14. What are Cookies
Cookies are tiny text files that are stored on your computer, tablet or mobile phone when you visit a website. They mean that the website will remember you and how you've used the site every time you come back.
If you want to know more about cookies, head to aboutcookies.org or allaboutcookies.org (please note: these links open a new window or browser tab).
We only use cookies based on your consent (except for strictly necessary cookies).

15. Links to Other Websites
Our website may contain links to third-party websites. Sweete is not responsible for the privacy practices or content of external websites. We encourage users to read the privacy policies of any websites they visit.

16. Changes to this Privacy Policy
Sweete may update this Privacy Policy from time to time to reflect changes in legislation, regulatory guidance, technology or our business practices. Any updates will be published on this page together with the revised "Last Updated" date.

17. Contact Us
If you have any questions about this Privacy Policy or the processing of personal data by Sweete, please contact: info@sweete.ie. If you are not satisfied with our response, or you believe your personal data has been processed in breach of applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission (Ireland).

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