Privacy Policy

1. Introduction

At DutyFreePulse, the protection of your personal data is fundamental to us and represents our commitment to maintaining your privacy. This Privacy Policy transparently informs you about what data we collect, how we process it securely, and what control options you have over your information.

Our data processing practices comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and the General Data Protection Regulation (GDPR) where it applies to our activities in tax-free shopping and savings optimization services.

2. Collection and Processing of Personal Data

The collection and processing of your data is exclusively purpose-based for the provision, implementation, and personalization of our tax-free shopping and savings optimization services. This includes:

2.1. Data you actively provide to us:

  • Registration data such as name, email address, phone number, shopping interests, and budget planning background
  • Payment information when booking tax-free shopping services
  • Feedback, shopping assessments, and communications as part of our shopping programs

2.2. Automatically collected data:

  • Technical information such as IP address, device type, and browser version when using our website
  • Service history and shopping program participation
  • Shopping preferences and development progress to optimize our service offerings

2.3. Cookies and tracking technologies: We use necessary cookies and, with your consent, analytics cookies to continuously improve our offerings. You can adjust your cookie settings in your browser at any time or use our website without optional cookies.

3. Purpose of Data Processing

We process your personal data for the following purposes:

  • Shopping Service Management – For the organization and personalized delivery of our tax-free shopping and savings optimization services
  • Client Administration – For the administration of registrations, bookings, payments, and sending relevant shopping program information
  • Progress Tracking – To record and monitor your shopping progress within our tax-free programs
  • Shopping Quality Assurance – For continuous improvement of our tax-free shopping service offerings

4. Legal Basis for Processing

Our data processing is based on the following legal foundations:

  • Contract performance in conducting tax-free shopping programs and administering client data
  • Legitimate interest in improving our shopping offerings and optimal design of our shopping programs
  • Fulfillment of legal obligations, particularly in the area of accounting
  • Your express consent when collecting certain shopping data and for shopping outreach measures

5. Disclosure to Third Parties

We share your data with third parties only in the following cases:

  • Payment Service Providers – For secure processing of payments for tax-free shopping programs and savings optimization services
  • IT Service Providers – For the operation of our client management systems and website as part of contracted processing
  • Shopping Partner Organizations – With your explicit consent, we may share relevant tax-free shopping information with budget partners or shopping referral organizations

We will not under any circumstances share your data with uninvolved third parties for advertising purposes.

6. Data Security

To protect your data with the highest security standards, we implement advanced security measures, including encrypted data transmission, secure storage, and strict access controls for our shopping staff. We take particular care to protect tax-free shopping-related and personal budget data.

Physical documents containing personal data are kept in locked cabinets and are securely destroyed after the statutory retention periods expire following secure disposal procedures.

7. Data Retention and Deletion

Your data is stored only as long as necessary for the specified purposes:

  • Contact and shopping contract data are stored for the duration of shopping engagement plus statutory retention periods.
  • Tax-free shopping data is retained for a maximum of 5 years after program completion for ongoing shopping support.
  • Payment data is stored in accordance with legal retention requirements for up to 7 years.

You have the right to request early deletion of your data at any time, provided there are no legal retention obligations to the contrary.

8. Your Rights

As a client, you have the following rights:

  • Access to the personal data stored about you
  • Correction of incorrect or incomplete data
  • Deletion of your data under the legally provided conditions
  • Restriction of processing under certain conditions
  • Data portability in a structured, commonly used format
  • Objection to processing based on legitimate interest

To exercise these rights, please contact us by email at privacy@dutyfreepulse.com or personally at our tax-free shopping center.

9. GDPR-specific Provisions

As a Canadian company with clients from the EU region, we follow the principles of the General Data Protection Regulation (GDPR) and guarantee the following rights:

  • Cross-border Data Transfers – When transferring data to countries outside the EU/EEA, we help that appropriate protective measures are taken, such as standard contractual clauses or adequacy decisions.
  • Data Protection Officer – Our Data Protection Officer is available for inquiries regarding the processing of your personal data and can be reached at privacy@dutyfreepulse.com.
  • Right to Lodge a Complaint – You have the right to lodge a complaint with a data protection supervisory authority, particularly in the EU Member State of your residence, workplace, or the place of the alleged infringement.
  • Data Minimization – We collect only data that is necessary for the stated shopping purposes and store it only as long as necessary and legally required.

For EU citizens participating in our tax-free shopping programs, additional special protective measures in accordance with the GDPR apply, including expanded information obligations and stricter consent requirements.

10. Changes to the Privacy Policy

We reserve the right to update this Privacy Policy as needed to accommodate legal requirements or organizational changes. The current version will always be published on our website and displayed in our premises.

In case of significant changes, we will inform our clients by email or through a notice in our premises.

If you have questions about data protection, we are available at any time in person, by phone, or by email. The protection of your data is not only a legal obligation for us but a fundamental responsibility and essential part of our tax-free shopping integrity and commitment to our shopping community members.