August 2025
We created Airtime to enhance the shopping experience of our members, providing a seamless service that gives moments of joy whilst making retail purchases. We believe loyalty and rewards programmes should be powered by great technology making them simple to operate and valuable for members. To deliver a truly seamless and personalised experience, we require our members to share their Personal Data with Airtime. We do not underestimate the importance and trust our members give to us in doing so and in this Privacy Policy we aim to provide transparency around how we hold and process Personal Data.
Airtime uses personal data for two main purposes:
Network Providers including Three – if you are a customer of one of these networks, we may use your data in additional ways and share it with the network providers who may use it for example for marketing purposes. For more details, please see the paragraph below.
This Privacy Policy sets out how and on what basis Airtime collects personal customer Data and how you and your data are protected when you use the Airtime apps and website.
Please read this Privacy Policy carefully to understand how we handle your data. If you have any questions about this Policy or how we process your Personal Data, please contact us.
Airtime has security policies and procedures referenced in our Terms. Complying with this will help you protect your own data.
Airtime cannot provide a rewards service without access to your personal data. If you do not want Airtime to use your data, we advise that the service might not be for you.
If you have any questions about our privacy policy or our collection, use, or storage of your personal data, please send an email to gdpr@airtimerewards.com
Airtime is the controller and responsible for your personal data (collectively referred to as “Airtime”, “we”, “us” or “our” in this privacy policy). Our company registration number is 08731821, England, and our registered office is:
Airtime Rewards Limited,
5th Floor,
Queens House,
Queen St,
Manchester,
M2 5HT
A Data Controller is a company or organisation that collects or stores personal data and can decide how that personal data is used. Airtime is a data controller.
Personal data under this Privacy Policy means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data usually includes someone’s name, a unique identification number, or an online registration number.
Airtime obtains your personal data when you use our applications, open an email, or correspond with us. Here is a list of the data that Airtime or third parties operating on our behalf may collect about you.
The legal basis for using your personal data are as follows:
(A) Consent: When you register a payment card or your bank account via open banking in connection with transaction monitoring, you authorise Airtime Rewards Limited to collect, process and share with its partners, as well as Visa, MasterCard, and/ or open banking providers and bank account providers, and other necessary payment service providers (Payment Service Providers) your payment card or bank account transaction information. We may not be able to provide our Services to you if you do not give your consent to such use of your personal data at the time of registration.
You authorise the Payment Service Providers relevant to you to monitor transactions on your registered card(s) or bank account registered via open banking (as applicable) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card or bank account registered via open banking (as applicable), and for such Payment Service Providers to share such transaction details with Airtime Rewards Limited to enable your card-linked offer(s) and target offers that may be of interest to you.
You may opt-out of transaction monitoring on the payment card(s) or bank accounts registered via open banking (as applicable) you have registered at any time by removing your payment card or bank account (as applicable) from your account. You can do this via the wallet section of the Airtime Application.
Information about Mastercard’s privacy practices is available in Mastercard’s loyalty privacy notice.
(B) Contractual performance: When you join our programme, you contract with Airtime to deliver our services as outlined in our Terms . We can only perform these services by processing your personal data.
(C) Legal obligations: We will also process your personal data where we are under a legal obligation to do so. For example:
(D) Legitimate interest: We also process your personal data based on our legitimate interest or the legitimate interests of others. Our legitimate interests are to:
You have a number of rights under data protection laws in relation to your personal data as more particularly described below. If you wish to exercise any of the rights set out below, please contact us. Please note, these rights are not always absolute rights and there may be occasions where we cannot agree or do not agree with your request – we will let you know where this is the case.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you wish to exercise any of the rights set out above, please email us at gdpr@airtimerewards.com. We aim to respond to all requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
There is generally no fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Airtime may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This security measure ensures that personal information is not disclosed to anyone with no right to receive it. We may also contact you for more information regarding your request to speed up our response.
In some circumstances, Airtime may not comply with personal requests to release or delete information if they conflict with Airtime’s obligation to comply with the company’s legal obligations or to establish, exercise, or defend legal claims.
Your personal data is processed and stored on secure computer systems located in the UK, European Economic Area, and the US – details of our service providers as at the date of this Privacy Policy are set out below.
If we provide any personal data about you to any of the above non-UK/non-EU suppliers, we will take appropriate measures to ensure that the recipient protects your personal data adequately under this Privacy Policy. These measures may include the following:
Service Providers
Other than what is described above, we will only share your personal data in a very limited way. This will happen where (1) it is in our legitimate interests to do so to run, grow, and develop our business, (2) we are under a duty to disclose it to comply with any legal obligation, or (3) in order to enforce or apply our Terms.
We may share your personal data with the following:
Our service providers (including their subcontractors). This may happen when they help us run our service or the technology systems needed to operate our website, applications, and services.
These are:
Regulators, and Law Enforcement
We may also share your data with:
Mobile Network Operators
Customers of mobile network operators who sign up for Airtime agree to share their Airtime data with their network, which are Airtime's partners, to allow for the application of credit to the customer’s mobile account.
This data is limited to the customer's phone number.
Mobile Network Operators: Three
Customers of Three who sign up for Airtime agree to share their Airtime data with their network, which are Airtime's partners, to facilitate in-depth customer satisfaction analysis, including Net Promoter Score (NPS).
Airtime and the Mobile Network Operators have a legitimate interest in ascertaining whether these customers score more highly than non-Airtime users.
Airtime will also share the data with these mobile network operators for marketing purposes. This data is limited to the customer's phone number, whether a card, open banking provider account or payment service provider account (as applicable) has been added to the account, whether a transaction has been made, the date of the last transaction, whether a redemption has been made and when, if applicable.
Airtime users can opt out of this data-sharing arrangement at any time by through the control settings in their profile page.
Airtime may provide information on Airtime marketing campaigns to different network providers with the results for measurement of performance. This data will not identify individuals.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We may also disclose and use anonymised, aggregated reporting and statistics about our applications and website to report to third parties for industry analysis (we might be paid for this) and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Save as expressly detailed above, we will never share, sell, or rent your personal data to any third party without notifying you and, where necessary, obtaining your consent.
Airtime processes your personal data to make suggestions designed to save you money by providing offers with our retail partners via our applications and website. We use your personal data to provide our applications and website and services as set out within this privacy policy.
We retain your information on our systems to match your details with new offers, retailers and to provide a gift card service. We use automatic processing or profiling to make automated decisions about you that generate and display these offers in our applications.
We want to share the benefits that Airtime can bring to all its consumers, so the data we collect might be used anonymously and aggregated in communications such as:
Any data we use to support the uses set out in the above bullet points is always anonymised and aggregated and can never be tracked to you personally.
Airtime Up is a premium service that allows you to earn more Rewards by linking your Bank Account to your Airtime account.
By linking your Bank Account you share additional data with us, including:-
We may use this Transactional Data to identify relevant offers from our retailer partners, so customers have the opportunity to save more money on their mobile phone bills. We also pool data, anonymising it to help identify trends in consumer spending.
By joining Up, you agree to our use of your personal data for the following purposes:-
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
When you close your account, Airtime anonymise and archives all personal data, which is kept for six months to fulfil legal and regulatory requirements. Airtime will do this if there is no conflict with our legal obligations.
If you believe we have broken data protection rules, then contact us in the first instance. You also have the right to complain to the Information Commissioner’s Office for breaches of UK GDPR, or the Data Protection Commission in Ireland (or your local European Supervisory Authority) for breaches of European Data Protection Law.
The ICO can be contacted at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113 (local rate) or 01625 545 745. Our ICO reference ID is ZA261320.
Information on how to contact the Irish Data Protection Commissioner is available at https://dataprotection.ie/en/contact/how-contact-us.
This website may include links to third-party websites, plug-ins and applications (for example social media platforms, apparel purchasing websites etc.) Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
We may update our Privacy Policy from time to time. Any changes we make to it in the future will be posted on this page and, where a material update is made, provided to you by email or in another appropriate manner.