Terms & Privacy
Last Updated: September 2026
This document governs the use of ohloyal
® ("ohloyal", “we”, “our”, “us”), including our website, platform, mobile applications, Apple Wallet passes, Google Wallet passes, NFC tags, and all related services (the “Services”).
By creating an account, purchasing a plan (including via Stripe or any in-app purchase provider), accessing pass files, downloading our mobile app, or using any ohloyal Services, you agree to these Terms & Privacy conditions.
1. Definitions
User – Any business, organisation, sole trader, individual acting for business or professional purposes, or other entity that creates an account with ohloyal and uses the Services.
End User – Any customer or individual who receives, accesses, downloads, stores, scans, or interacts with a loyalty pass (including Apple Wallet or Google Wallet passes), NFC tag, or other digital content created by a User.
Visitor – Any person who visits our website but does not create an account.
ohloyal acts as:
- Data Controller for User account, billing, platform, and business relationship data.
- Data Processor for End User data processed on behalf of a User.
The User acts as the Data Controller for End User personal data collected, processed, stored, or used through the Services and is responsible for complying with all applicable data protection and privacy laws.
2. Privacy
2.1 Legal Compliance
ohloyal operates in accordance with applicable data protection laws, including but not limited to:
- UK GDPR and Data Protection Act 2018
- EU General Data Protection Regulation (EU) 2016/679
- Applicable United States federal and state privacy laws (including CCPA/CPRA where applicable)
- Other applicable international privacy regulations
2.2 Data We Collect
Technical Data Collected Through the Services:
This may include IP address, browser information, device data, analytics, cookies, and similar technical or usage information
From Visitors:
This may include voluntarily submitted contact details.
From Users (Businesses):
This may include name, business name, contact details, billing information, transaction records, account activity, communications, and support requests.
From End Users:
Only where enabled by the User’s plan and settings. This may include:
- Name
- Email address
- Telephone number
- Birthday
- Custom fields defined by the User
- Marketing consent status
- Loyalty activity and interaction data
ohloyal does not determine what personal information a User chooses to collect from End Users through configurable data collection features.
The Services are not intended for the storage of medical records, clinical information, diagnoses, treatment information, or other sensitive health information.
Users are responsible for ensuring that personal data entered into the Services is appropriate for the Services and processed in accordance with applicable data protection laws.
2.3 Marketing & Data Collection Features
Some subscription plans allow Users to collect End User data and send marketing communications.
If enabled by the User:
- The User is solely responsible for obtaining lawful, informed consent.
- The User must comply with GDPR, PECR (UK), CAN-SPAM (US), and any applicable marketing laws.
- ohloyal provides technical tools only and does not control marketing content or purpose.
All legal responsibility for communications sent by a User rests solely with that User.
2.4 Data Responsibility
The User is fully responsible for:
- Lawful basis for processing
- Consent collection and storage
- Data accuracy
- Responding to data subject requests
- Retention and deletion policies
- Security of exported or downloaded data
ohloyal processes End User data strictly on documented instructions from the User.
2.5 Security
We implement appropriate technical and organisational safeguards.
However, no system can guarantee absolute security, and use of the Services is at your own risk.
2.6 Retention
User data is retained for the duration of the account and as required by law.
End User data remains under the control of the User and is deleted upon account termination, subject to legal obligations.
2.7 International Transfers
Where personal data is transferred internationally, safeguards such as Standard Contractual Clauses or equivalent legal mechanisms are implemented where required.
2.8 Use of reCAPTCHA (Anti-Bot Protection)
To protect our Services from spam, abuse, and automated misuse, ohloyal may use anti-bot and security verification services, including Google reCAPTCHA.
These services may collect and process information including:
- IP address
- Browser and device information
- User interaction data (such as mouse movements, clicks, and timing)
- Cookies and similar tracking technologies
This data is used solely for security, fraud prevention, and service integrity purposes.
Where reCAPTCHA or similar technologies are used, data may be processed by Google as a data processor acting on our behalf.
The legal basis for this processing is our legitimate interest in protecting our platform, Users, and End Users from fraudulent or abusive activity. Where required by law, such technologies may be subject to user consent mechanisms.
2.9 Wallet Platform Features & Location Relevance
Apple Wallet and Google Wallet may use device-based features such as location relevance, lock screen suggestions, notifications, location-based functionality, and pass presentation when a user is near a location associated with a pass.
These features are provided and controlled by Apple, Google, the user's device, and the user's operating system settings.
End Users may disable such features or remove a pass at any time through their device settings.
ohloyal does not receive, collect, store, monitor, or track the real-time location of End Users through these wallet platform features unless explicitly stated otherwise.
Where a User configures pass locations or location-based functionality, the User is responsible for ensuring any required notices, disclosures, lawful basis, or consents are obtained in accordance with applicable law.
2.10 EU GDPR Data Processing
Where ohloyal processes End User personal data on behalf of a User, the User is the Data Controller and ohloyal is the Data Processor under Article 28 EU GDPR. Processing is limited to providing the Services, for the duration of the User's account, and to the types of End User data described in these Terms.
ohloyal will process such data only on documented instructions from the User, maintain appropriate confidentiality and security measures, and provide reasonable assistance with applicable data subject and GDPR obligations where required by law.
The User authorises ohloyal to use sub-processors where necessary to provide, host, secure and support the Services. Applicable sub-processors will be subject to appropriate data protection obligations.
Users remain responsible for the personal data they choose to collect, their lawful basis, required notices and consents, marketing activities, and responding to their End Users. Users can manage and delete End User data through the Services.
Upon termination, End User data will be deleted in accordance with our retention practices unless retention is required by law. ohloyal will provide information and reasonable cooperation necessary to demonstrate compliance with its applicable Article 28 obligations.
Where ohloyal becomes aware of a personal data breach affecting End User data processed on behalf of a User, ohloyal will notify the affected User without undue delay as required by applicable data protection law.
3. Terms of Use
3.1 Service Provision
ohloyal provides software that enables Users to create and distribute digital loyalty passes for Apple Wallet and Google Wallet, and to use NFC tags for pass distribution.
We do not control:
- Content created by Users
- Offers or rewards issued by Users
- Business practices of Users
- Disputes between Users and End Users
All promotions, rewards, and representations are the sole responsibility of the User.
3.2 System Accuracy, Reward Tracking & Technical Errors
ohloyal provides automated tools for tracking loyalty activity, including stamp counts, reward balances, and eligibility indicators across Apple Wallet passes, Google Wallet passes, and NFC-enabled distribution.
We do not guarantee that loyalty tracking, stamp totals, reward calculations, pass updates, or system notifications will be error-free, uninterrupted, secure, or immune from misuse or manipulation.
Users are solely responsible for independently verifying reward eligibility before issuing any reward, benefit, discount, or promotional item.
ohloyal shall not be liable for:
- Software bugs, display errors, or synchronization delays
- Incorrect reward calculations or inaccurate stamp or point counts
- Duplicate, manipulated, or fraudulently obtained stamps or points
- Exploitation of technical vulnerabilities
- Losses arising from system malfunctions or technical interruptions
- End Users relying on incorrect balance or reward information
In the event of a system error, ohloyal reserves the right to correct inaccuracies without liability and without obligation to compensate Users or End Users for any perceived loss.
3.3 Mobile Apps & App Stores
If you download our mobile application via Apple App Store or Google Play:
- These Terms are between you and ohloyal only.
- Apple and Google are not responsible for the Services.
- Apple and Google have no maintenance or support obligations.
- To the maximum extent permitted by law, Apple and Google have no warranty liability relating to the app.
3.4 NFC & Device Compatibility
We do not guarantee compatibility with all devices, operating systems, wallet platforms, or NFC functionality.
ohloyal is not liable for:
- Device malfunction
- Software conflicts
- Battery drain
- Data loss
- Wallet platform restrictions
- Third-party service outages
3.5 Subscription Limits
Each plan includes usage limits (including app installations, NFC tags, API, and features).
Expanded limits may be purchased where available.
3.6 Cancellations & Strict No Refund Policy
Users may cancel at any time through their account settings.
All payments are final and non-refundable.
By purchasing any subscription (including via Stripe or in-app purchase), the User expressly acknowledges that:
- Access to digital services is provided immediately upon payment.
- No refunds will be issued for unused time, partial billing periods, downgrades, or non-use.
- Chargebacks or payment disputes made in bad faith may result in immediate account suspension.
- Refunds, if granted, are issued solely at ohloyal’s absolute discretion in exceptional circumstances only.
This policy applies to monthly, annual, promotional, and upgraded plans.
3.7 Limitation of Liability
To the fullest extent permitted by law:
- ohloyal shall not be liable for indirect, incidental, consequential, special, punitive, or exemplary damages.
- Total liability shall not exceed the amount paid by the User in the preceding 3 months.
- We are not responsible for User-generated content or misuse of End User data.
- We are not responsible for legal claims arising from a User’s promotions, marketing, or data handling.
3.8 Indemnification
The User agrees to indemnify, defend, and hold harmless ohloyal, its directors, officers, employees, and affiliates from any claims, damages, losses, liabilities, costs, or legal fees arising from:
- Content created by the User
- Offers or rewards issued by the User
- Violation of applicable law
- Misuse of personal data
- Disputes between User and End User
- Regulatory investigations triggered by the User’s conduct
3.9 Acceptable Use
Users must not use the Services for unlawful, fraudulent, misleading, harmful, or abusive purposes.
We reserve the right to suspend or terminate accounts at our discretion.
4. Governing Law
These Terms shall be governed by and construed in accordance with the laws of England and Wales.
Any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.
5. Changes to These Terms
We may update these Terms at any time. Continued use of the Services after updates constitutes acceptance of the revised Terms.
6. Contact
For legal or data enquiries:
hello@ohloyal.com