Privacy Policy

Last Updated: August 18, 2026


This Privacy Policy explains how information about you is collected, used and disclosed by CdeCompany, LLC (collectively, “CdeCompany,” “we” or “us”) when you use our website https://app.ldeloyal.com (“Website”) and customer loyalty program services (“Platform”) (collectively, “Services”), or when you otherwise interact with us. This Privacy Policy also describes your choices regarding use, access and correction of personal information collected about you through our Services. Please read this Privacy Policy carefully and ensure that you understand it before you start to use our Services.

This Website is owned and operated by, or on behalf of, CdeCompany, LLC (“we”, “our” or “us”). We are the data controller (or “responsable del tratamiento” under applicable Latin American data protection laws) in respect of personal information of our users, wherever they are based, including users in Latin America and the European Union, except with respect to Customer PI (as described below), for which our customer is the data controller and we act as a data processor (“encargado del tratamiento”).

By accessing and using the Services, you acknowledge that you have read and understood the content of this Privacy Policy. We reserve the right to update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

INFORMATION YOU PROVIDE TO US THROUGH THE SERVICES


We collect and process information you provide directly to us via the Services. Personal data submitted through the Services include the details you submit when you create an account, participate in any interactive features of the Services, pay for purchase orders, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, company name, postal address, phone number and any other information you choose to provide. To the extent you provide credit card information through the Services, that information is collected and processed by our third-party payment processor pursuant to their Privacy Policy and practices. Our payment processor is Stripe and their privacy policy can be found here https://stripe.com/privacy .

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES


When you access or use the Services we automatically collect information about you, including:

  • Log Files: We gather certain information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Services, and store it in log files. We do not monitor or log data collected from your servers when using the Services, but we may log or monitor information about your access to our Services.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. For more information about cookies, and how to disable them, please see our Cookie Policy page https://ldeloyal.com/cookies; and Your Choices below. Where required by applicable law, we will request your consent before placing non-essential cookies on your device.

INFORMATION WE COLLECT FROM OTHER SOURCES


We may also obtain information from other sources and combine that with information we collect through our Services for purposes of advertising and user authentication. For example, if you create or log into your CdeCompany account using your Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Google Apps profile settings.

USE OF INFORMATION


We may use information about you to:

  • Enable you to have full access to the Services;
  • Provide, maintain and improve the Services;
  • Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
  • Send you technical notices, updates, security alerts, and support and administrative messages;
  • Respond to your comments, questions and requests, and provide customer support;
  • Create your CdeCompany account and identify you when you sign-in to your account in accordance with your agreement with us;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by CdeCompany and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with the Services;
  • Detect, investigate and prevent fraud and other illegal activities and protect the rights and property of CdeCompany and others;
  • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
  • Notify you about important changes to the Services, including changes or updates to this Privacy Policy;
  • Link or combine with information we get from others to help understand your needs and provide you with better service;
  • Consider you for possible employment at CdeCompany in connection with an application that you submit; and
  • Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION


We may share your personal information as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers we have vetted and approved who need access to such information to carry out work on our behalf only to the extent necessary for the performance of any contract we enter into with you;
  • In response to a request for information if we believe disclosure is permitted by, in accordance with, or required by, any applicable law, regulation or legal process such as to comply with a subpoena or applicable court order;
  • With any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under any agreement we enter into with you or to protect the rights, property and safety of CdeCompany or third parties;
  • In connection with, or during negotiations of, any merger, sale of CdeCompany assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among CdeCompany and all companies affiliated with CdeCompany who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
  • With analytics and search engine providers that assist us in the improvement and optimization of our Website, subject to our Cookies Policy; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. We do not sell your personal information.

LAWFUL BASIS FOR PROCESSING YOUR INFORMATION


Where required by applicable data protection law (including the GDPR and the data protection laws of Latin American jurisdictions such as Chile, Brazil, Mexico, Colombia, Peru, Argentina and Ecuador), we process your personal information on the following lawful bases:

  • Your prior, express and informed consent, where consent is the required legal basis for the processing concerned (for example, in relation to direct marketing or where local law makes consent the default legal basis for processing). You may withdraw your consent at any time;
  • The performance of a contract to which you are a party, including providing the Services you have subscribed to;
  • Compliance with a legal obligation to which we are subject; or
  • The legitimate interests pursued by us in promoting our business, providing the Platform to our customers pursuant to our legal agreements with them, and in ensuring the security, accessibility and improvement of our Website and Platform and the development of new technology and services, where such interests are not overridden by your rights and freedoms.

EXTERNAL LINKS


The Website may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. We are not responsible for the privacy policies or the content of such sites.

LOG-IN FEATURES


We may allow you to sign up and log in using your Google account. If you sign up using your Google email account, Google will ask your permission to share certain information from your Google account with us. This may include your first name, last name, gender, general location, your timezone and birthday. This information is collected by Google and is provided to us under the terms of Google’s privacy policy, which you can find here:  https://policies.google.com/privacy?hl=en-US. You can control the information that we receive from Google using the privacy settings in your Google account.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS


We allow the following companies to serve advertisements on our behalf across the Internet and in applications: Google AdWords, Google Analytics, Meta (Facebook and Instagram), Microsoft (Bing Ads and Clarity), LinkedIn, and Twitter/X, using email address and cookies that are collected. These entities use technologies including cookies, web beacons, device identifiers and other tools to collect information about your use of the Services and other websites and applications, including your IP address, web browser, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by CdeCompany and CdeCompany service providers to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about cookies, please see below and for further information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please see CdeCompany’s Cookie Policy at https://ldeloyal.com/cookies.

INFORMATION COLLECTED ON BEHALF OF CUSTOMERS IN PROVIDING OUR PLATFORM


In the case of personal information we handle or receive on behalf of a customer in connection with their access to, and use of, our Platform — for example, the names, contact details, birth dates, visit and purchase history, loyalty points, rewards and approximate location data of the end customers participating in a loyalty program operated by one of our customers (“Customer PI”) — the applicable customer (the business operating the loyalty program) is the data controller (“responsable del tratamiento”) of that information, and CdeCompany acts solely as a data processor (“encargado del tratamiento”) on the customer’s behalf and under its instructions. We have no direct relationship with the end customers or other individuals with whom that customer may interact with respect to the Platform. If you are such an end customer or individual and are seeking access to, or would like to correct, amend or delete, Customer PI, you should direct your query to the applicable customer (the business whose loyalty program you joined). We will respond within a reasonable timeframe to a customer’s request to remove Customer PI, and we will support our customers as reasonably necessary for them to respond to requests from individuals exercising their rights under applicable data protection laws. A data processing agreement governing our processing of Customer PI is available to customers upon request (see the Subscription Agreement).
We will not use Customer PI except for the purpose of providing and supporting the Services for the applicable customer. Customer PI will be retained for as long as needed for that purpose and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

MARKETING


Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing and to provide you with promotional update communications by email about our products/services. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional electronic communications to you, or by contacting us using the contact details set out at in the Your Choices and Your Rights sections of this Privacy Policy.

SECURITY


We take reasonable steps, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. In the event of a personal data breach affecting your personal information, we will notify you and the competent authorities where and as required by applicable law. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us.

Your personal information will be retained by CdeCompany for the duration of your account and may be retained for a period after this time as necessary and relevant to our legitimate interests, our terms of agreement with you and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings.

We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.

CHILDREN’S PRIVACY


Our Services are intended for businesses and are not directed to children. We do not knowingly collect personal information directly from children under the age of 14 (or the equivalent minimum age in your jurisdiction). Where a customer uses the Platform to process personal information of minors as part of its loyalty program, the customer, as data controller, is responsible for obtaining any consent or authorization required by applicable law (such as the consent of a parent or legal guardian). If you believe that a child has provided us personal information without appropriate consent, please contact us at [email protected] and we will take reasonable steps to delete such information.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES


CdeCompany is based in the United States. By accessing or using the Services or otherwise providing information to us, you understand that your information will be subject to processing, transfer and storage in and to the U.S. and other countries, where data protection laws may differ from those of your country of residence. Where required by applicable data protection law (including the laws of Chile, Brazil, Mexico, Colombia, Peru, Argentina, Ecuador and the European Union), we implement appropriate safeguards for international transfers of personal information, such as contractual data protection clauses with the parties receiving the information, and, where applicable, we rely on your consent or another lawful transfer mechanism recognized by the law of your jurisdiction. You may contact us at [email protected] for more information about the safeguards we use.

YOUR RIGHTS — LATIN AMERICA


If you are located in a Latin American jurisdiction with a data protection law — including, without limitation, Chile (Law No. 19,628 and Law No. 21,719), Brazil (the LGPD, Law No. 13,709/2018), Mexico (the Federal Law on the Protection of Personal Data Held by Private Parties), Colombia (Law No. 1,581/2012), Peru (Law No. 29,733), Argentina (Law No. 25,326), Ecuador (the Organic Law on Personal Data Protection) or Uruguay (Law No. 18,331) — you have rights over your personal data, which, depending on your jurisdiction, include the rights of access, rectification, cancellation/erasure, objection (the “ARCO” rights), data portability, the right to withdraw your consent at any time without retroactive effect, and the right not to be subject to decisions based solely on automated processing that produce legal effects concerning you. You may exercise these rights, free of charge, by emailing us at [email protected] with the subject line “Data Rights Request”, indicating your name, your country of residence and the right you wish to exercise. We will respond within the timeframe required by the applicable law of your jurisdiction. If you believe your rights have been infringed, you also have the right to file a complaint with the data protection authority of your country (for example, the Agencia de Protección de Datos Personales in Chile, the ANPD in Brazil, the competent authority under Mexican law, the Superintendencia de Industria y Comercio in Colombia, the Autoridad Nacional de Protección de Datos Personales in Peru, or the Agencia de Acceso a la Información Pública in Argentina).

If the personal data concerned is Customer PI (that is, data processed on behalf of the business whose loyalty program you joined), please direct your request to that business, which is the data controller; we will refer any request we receive to that customer and will support them as needed to respond to your request.

YOUR RIGHTS — EUROPEAN UNION


EU individuals have rights in relation to their personal data, which is processed by CdeCompany. If you are an EU data subject, you may, by emailing us at [email protected]:

  • Request access to the personal data concerned.
  • Request that any incorrect personal data about you that we are processing be rectified.
  • Request that we erase the personal data concerned.
  • Withdraw your consent at any time where we are processing personal data relating to you on the basis of your prior consent to that processing, after which we shall stop the processing concerned.
  • Lodge a formal complaint with the data protection supervisory authority of your country of residence if you have a complaint about any processing of your personal data being conducted by us.

If the requested data is Customer PI, please include the name of the applicable customer in your request; we will refer the request to that customer to respond directly to you and will support them as needed to respond to your request.

YOUR CHOICES


Account Information

Our customers may access, update or change personal information they have provided by logging into the Services or emailing us at [email protected].
Subject to the terms of their agreements with us, Customers may deactivate their accounts by emailing us at [email protected], but note that we may retain certain personal information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also retain cached or archived copies of personal information for a certain period of time.

If you are an individual with whom one of our customers interacts with respect to the Services (e.g., an end customer of a business using the Platform), as noted above, you should direct any requests regarding access, modification or deletion of personal information to the applicable customer.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information, please see CdeCompany’s Cookie Policy at https://ldeloyal.com/cookies.

Promotional Communications

You may opt out of receiving promotional emails from CdeCompany by following the instructions in those emails or by emailing [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.


CONTACT US


If you have questions or concerns about this Privacy Policy, or wish to exercise any of your rights, please contact us at:

CdeCompany, LLC
131 Continental Dr Suite 305, Newark, DE 19713, USA
Email: [email protected]