Identification data
Phone number or e-mail, name, card number. Without them a card cannot be tied to a person.
Every loyalty program stores personal data: a phone number, a name, a purchase history. That is why the Moldovan data protection law, Law No. 195/2024, concerns any store with a customer card, from a single shop to a chain. Below is a plain-language guide to what an owner or marketer should look at. It is not legal advice: have the consent texts and the privacy policy reviewed by a lawyer.
What data a loyalty program collects
Start with an inventory: what exactly do you hold, and why? A typical set looks like this.
Purchase data
Receipts, amounts, products, stores, bonuses. They form the customer profile and the rhythm of visits.
Communication data
Consents for messages, the chosen channel, the history of messages sent.
Optional data
Date of birth, gender, city. Ask for them only if a specific rule needs them, for example a birthday offer.
A simple test for every field on your form: which rule or report is built on it. If there is no answer, do not ask for the field. Less data means lower risk and less work when a customer makes a request.
Customer rights
Data protection laws, here and elsewhere, are built around the rights of the individual. In practice a store must be able to answer requests like these:
- Show what data is stored about a person and where it came from
- Correct wrong data
- Delete or anonymize data when there is no longer a reason to keep it
- Withdraw consent for marketing messages as easily as it was given
Check the exact list of rights, response deadlines and exceptions against the text of the law and with a lawyer. For a store the more important question is different: do you have a procedure? Who receives the request, who answers and within what time, where the result is recorded. If the answer is "we will write to the programmer", the process is not ready.
Consent: service and marketing
The most common practical mistake is one general "I agree to everything" box when a card is issued. It is safer to separate things:
Processing consent
Weak practiceHidden in the small print of the form
Good practiceA separate, clear text: why, what we collect, how long we keep it
Marketing
Weak practiceOn by default
Good practiceOff by default, the customer turns it on
Opting out
Weak practiceMust call or write to the store
Good practiceA switch in the app or a link in the message
Proof
Weak practiceNo trace of who agreed and when
Good practiceDate, wording and channel of the consent are recorded
Service messages (a login code, a change in the bonus balance) and marketing messages ("a discount on coffee") should be kept apart: they have different legal grounds and different expectations from the customer.
Example. A cashier registers a card by phone number. The customer receives a message with a login code: that is a service message. Marketing messages the customer switches on separately, in their own profile, and can switch off at any time.
Storage, access and sharing
Customer data must be protected not only on paper but also in the system.
Who has access
Staff rights by role: a cashier needs the receipt, a marketer needs the segment, and the full list of phone numbers should be available to few people.
Where the data is stored
Know on which server and in which country the database sits, and who manages it: you or a contractor.
What happens when data is shared
Exports to spreadsheets, messaging services and contractors should be known and recorded. A file of phone numbers forwarded to a personal mailbox is out of your control.
How long data is kept
Set a retention period and decide what happens to inactive customers.
How actions are recorded
A log of sign-ins and changes helps clarify an incident.
If something goes wrong
A data leak or a wrongly sent mailing can happen in any store. Decide three things in advance: who on the team is responsible for such cases, how quickly they find out about an incident and how you inform customers and, if the law requires it, the supervisory authority. Clarify deadlines and procedure with a lawyer. A good system helps in two ways: the log shows what happened, and role-based rights narrow the circle of people who could have made the mistake.
Where to start
A short plan for the next month to put the program in order:
Make a data register
Which fields are collected, on which screens and in which documents.
Rewrite the consents
Service and marketing separately, in the customer's language, with date and channel.
Name a responsible person
One person receives customer requests and knows what to do.
Check access
Who sees phone numbers and purchase history, and whether each of them needs it.
Check paper forms separately. A form filled in at the till and typed into the system later is one of the most vulnerable points: the paper sits in a drawer and nobody remembers how many forms are there. It is better to enter the data directly into the system and not to keep the paper.
What to ask your vendor
Before choosing a loyalty system, ask the questions and ask to be shown the answer, not to read a slide:
- How does a customer withdraw marketing consent and where is it visible in the system
- Can all data of one person be exported and then deleted or anonymized
- Are marketing consents on or off by default
- How are staff rights separated and is there a log of actions
- Where is the system hosted and can you choose the hosting
- How is security checked: are there automated tests, including attack scenarios
How Synngate Loyalty handles it
In the customer app people can download their data and delete their account, and marketing consents are off by default. Sign-in is passwordless and a customer sees only their own data. Security is checked by hundreds of automated tests, including attack scenarios. The solution takes the requirements of Law No. 195/2024 into account; hosting is possible in our cloud or on your own server. Details are on the security page, and the app is described separately.
Want to see how consents and customer requests look? Request a demo.
Frequently asked questions
Does Law 195/2024 apply to a small store?
Yes, if you collect personal data: a phone number, a name, a purchase history on a card. The size of the store does not remove the duty, though the amount of work for a small shop is usually lower.
Can I send marketing to every cardholder?
Only to those who have given consent. Service messages and marketing differ, so keep a separate marketing consent.
What if a customer asks to delete their data?
You need a procedure: receive the request, verify identity, delete or anonymize the data and record the result. Receipt history is sometimes kept anonymized for accounting; agree the details with a lawyer.
Is it enough to buy a system that is "compliant"?
No. A system helps, but consents, internal rules and staff training stay with the store.