Delete Memberships (Right to Be Forgotten)

When a member asks to have their personal data erased or asks to be removed from the loyalty program, you can delete their membership (along with their personal data) using the process described below.

Article Topics:

How It Works
Step 1- Request
Step 2 - Benefits
Step 3 - Delete
After Delete...
Setup & Preparation


How It Works

  1. Member requests to have their data deleted via new app legal screens (or other ways like app feedback).
  2. Business must make alternative arrangements for certain types of member benefits.
  3. Membership is deleted through the Hub with their personal data and benefits within 14 days.

1 – Request


Members can request to have their data deleted (which will result in their removal from the loyalty program)—using the new legal screen in the member profile or in other ways (like via feedback). Here’s the main app user flow:

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Once the request is sent:

  • Email notification is automatically sent to the business (and other feedback emails), Como support, and Como legal
  • Member is unsubscribed from marketing SMS and emails
  • Log is shown in the Hub member profile: Member requested to delete their membership and personal details

Note: Como only monitors requests that are made from the app legal screens.


2 – Benefits


Member benefits are divided into two groups:

Group

Examples

Until the membership is deleted (and within the 14 days)…

Accrued assets

Gifts, points

Member can still use and accumulate them.

Unique assets

Purchased coupons, gift cards

Business must: 1) refund them or allow the member to use them directly through the business; 2) remove this asset from member (Hub profile)



3 – Delete


Within the 14 days, the business must delete the member’s personal info as follows:

  • Click Delete Membership in Hub profile to erase their name, phone, email and home address.
  • Manually erase any additional info they collected or stored that could identify the member.
  • Erase any personal info they saved locally (such as exported reports).
  • Delete their details from marketing messages (SMS or email) distribution lists that aren't managed by Como.
  • Notify any relevant 3rd party (like POS, ordering, payment, or marketing messaging solutions) to erase any info that was shared with them from their databases within the 14 days.

After Delete…


What happens when you click Delete Membership in the Hub?

  • PII—name, phone, email, address, official ID number, external member ID, custom fields are anonymized
  • Old PII—previous PII that was updated is also erased (ex: old address before they updated it)
  • Actions—our data & BI still counts the past actions, but you can’t view their personal info
  • POS—Member can no longer be identified at the POS (getMemberDetails returns an error)
  • Benefits—Member can no longer accumulate or use any accrued assets (like gifts and points).
  • App—Member is automatically logged out of the app.
  • Log—Log is shown in the Hub member profile: Membership and personal details has been deleted

In general, all exported reports that were generated from the Hub more than a year ago are deleted so that the PII will not be available in these past reports.

Note: If the business didn’t delete the membership within the 14 days, Como will delete the member’s personal info (only if the request was sent via app legal screens).

Setup & Preparation


Here’s what’s required to enable the above flow:

  • New Layout—App must be updated to the new layout of the profile screen (all apps will be updated gradually before the GDPR takes effect, and old layouts will no longer be available).
  • Email—Business email address should be updated so they receive the email notification (by updating feedback addresses in app text: FeedbackTile.MailTo).
  • Permission—Business must get the Hub permission needed to view the Delete button.
  • Communication—Business must understand the new flow, and their responsibilities.
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