Privacy Policy

Introduction

We take your privacy very seriously and we are committed to complying with applicable data protection laws in the jurisdictions where we operate. Your personal information may be processed in accordance with local legal requirements, including but not limited to data protection regulations such as the UK GDPR in the United Kingdom, the EU GDPR in the European Union, and the Privacy Act 1988 in Australia, and other relevant laws in your region.

Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We keep our privacy policy under regular review. This version was last updated  in April 2025. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. 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.

Third-party apps, websites and services
If you use any third party apps, websites or services to access our services, your usage is subject to the relevant third party's terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform.

Who are we?

When we say ‘Tillo’ ‘we’ or ‘us’ in this policy, we are referring to one or some of the companies that make up the Tillo Group. The companies that currently make up the group are:

• Reward Cloud Limited: Unit 14, Hove Business Centre, Hove, BN3 6HA;
• Jigsaw Business Solutions Ltd: Unit 14, Hove Business Centre, Hove, BN3 6HA;
• Tillo, Inc: Penn Field, Suite C304, 3601 S Congress Ave, Austin, TX 78704; and
• Tillo Pty Limited: Grant Thornton Australia, Level 17, 383, Kent Street, Sydney NSW 2000, Australia.

Tillo is the data controller and is responsible for certain personal data about you that we collect and use as a consequence of: 

• you applying for a job vacancy via our Careers website ;
• Tillo providing our services via our global rewards and incentives platform to the organisation that you represent (our ‘Clients’), including: 
  • Tillo providing its gift card management programme, where the organisation that you represent issues gift cards); and 
  • Tillo reselling and/or distributing gift cards to the organisation that you represent (where the organisation you represent purchases gift cards as part of B2B sales);

• Tillo distributing and/or reselling the gift cards issued or distributed by your organisation (our ‘Suppliers’);
• Tillo connecting the organisation that you represent with our Clients so gift cards issued by such Clients could be sold to your organisation (the ‘Buyers’); and you using or browsing our website. 
  
  

We may also act as processor of some consumers’ or end users’ (i.e. our Clients’ customers) personal data that we receive from or collect on behalf of our Clients, which are acting as controllers in this case. This is so that we can provide our services to our Clients, and our legal obligations as a processor are instead set out in the contract between us and the relevant controller and the relevant privacy obligations applied.

What personal data do we collect about you? 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Job applicants

• Identity Data: includes name and job title.
• Contact Data: includes email address, telephone numbers, address, (where applicable) online presence.
• Work Experience Data: includes your resume, cover letter, recruitment information (e.g. right to work documentation and references), test results (incl. technical test and coding exercises), current and expected salary and any additional information we may receive from our recruitment partners.
• Marketing Data: includes your preferences in receiving updates on job opportunities at Tillo. 
  
  

Representatives of our Clients 

• Identity Data: includes name and job title. 
• Contact Data: includes business address, email address and telephone numbers, organisation details, (where applicable) online presence.
• Profile Data: includes your username, orders made by you on behalf of your organisation, your interests, preferences, feedback.
• Usage Data: includes information about how you use our website and products.
• Marketing Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  
  

Representatives of our Suppliers and Buyers

• Identity Data: includes name and job title.
• Contact Data: includes business address, email address and telephone numbers.  
  
  

Website users

• Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data. 
• Usage Data: information about how you use our website, IT, communication and other systems.
  
  

If you apply for a job vacancy via our Careers website, you can optionally choose to fill out a survey form by answering some questions about yourself, including your gender identification, ethnicity, and sexual orientation. This information is stored separately from your application and anonymised at the point of collection by Ashby, Inc. As such, Tillo is unable to link your survey answers to you as an individual; consequently, such data does not qualify as personal data.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data is derived from your personal data but is not considered personal data under the law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We collect and use this personal data for the purposes described in the section ‘how and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing products to you or your organisation.

How do we collect your personal data?

We collect some of this personal data directly from you in person (for example, by telephone, email and/or via our forms hosted on the Tillo website). However, we may also collect information from: 

• from publicly accessible sources (for example, LinkedIn);
• when you apply for a role with Tillo via our Careers portal, we collect your information from Ashby, Inc. who provide us with the online software for our application tracking system and application portal; 
• the organisation that you represent (our Clients, Suppliers and Buyers); 
• other organisations within the gift cards industry (for example, Clients may provide us with personal data about representatives of prospective Suppliers and vice-versa); and
• from cookies on our website—for more information on our use of cookies, please see our cookie policy below. 

How and why do we use your personal data?

Under data protection law, we can only use your personal data if we have a lawful basis, such as for our legitimate interests or those of a third party, where you have given consent, or to comply with our legal and regulatory obligations.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. 

The table below explains how and why we use your personal data.

Marketing

We may use your personal data to send you marketing communications and updates about our products.

You have the right to opt out of receiving marketing communications at any time by clicking on the unsubscribe link within our emails. 

We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

Cookies policy
A cookie is a small file placed on your device when you access a website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 
Below is a list of cookies that we collect in line with the website permissions that you select.  

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Who do we share your personal data with?

We routinely share personal data with:

• third parties we use to help deliver our services and run our business, e.g. cloud storage providers, digital development companies, CRM system providers, marketing agencies or website hosts and IT and systems administrators;
• if you’ve applied for a role with Tillo, Ashby, Inc., we share your information with Ashby, Inc., who provide us with the application tracking software used by Tillo to progress your application and contact you about any updates regarding your application;
• other companies within the Tillo Group;
• if you are a representative of a Customer, we may also share your information with our Suppliers, as applicable, to facilitate your agreement with us, and vice versa;
• if you are a representative of a Buyer, we share your information with our Clients who issue gift cards, to facilitate the selling of gift cards from them to you; and our bank.
  
  

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

• our external auditors (for example, in relation to the audit of our accounts) in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
  
  

International data transfers
As a global platform, we may transfer and store your information in locations outside your country of residence. By using our services, you acknowledge that your information may be transferred to jurisdictions that may have different data protection laws from your own.

In those cases we will comply with applicable laws designed to ensure the privacy of your personal data. In particular, whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or 
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact us by emailing us at privacy@tillo.io if you want further information on the specific mechanism used by us when transferring your personal data internationally.

How long will your personal data be kept for?

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.

Please contact us by emailing us at privacy@tillo.io if you want further information about how long we will retain your personal data. 

What are your rights in relation to the processing of your personal data?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.

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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
• 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.
  
  

If you wish to exercise any of these rights please contact privacy@tillo.io.

No fee usually required
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
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.

Complaints

If you are located in the United Kingdom (UK), European Union (EU), or Australia and believe that your data privacy rights have been violated, you have the right to file a complaint with the appropriate regulatory authority (see below). We would, however, appreciate the chance to deal with your concerns before you approach a regulatory authority, so please contact us in the first instance:

• UK: You can make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection at this link.
  
  
• EU: You can lodge a complaint with your local supervisory authority if you believe that your personal data has been processed in a manner that violates the EU GDPR. Contact details for EU supervisory authorities can be found here.
  
  
• Australia: You can file a complaint with the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC to lodge a complaint at this link.
  
  

Contact us

If you have any questions about this policy or about how we handle your data, please contact our data privacy team as follows:

Email: privacy@tillo.io.