Loyalty Program Terms and Conditions

Effective Date: 02/04/2026

Last Updated: 02/04/2026

Version: 1.0

1. General Provisions

1.1. These Loyalty Program Terms and Conditions (hereinafter — “Terms”) govern participation in the Loyalty Program (hereinafter — “Program”) operated by DPO Europe GmbH (hereinafter — “Organizer”, “we”, “us”, or “our”).

1.2. Organizer:

DPO Europe GmbH

Auguste-Viktoria-Allee, 20A

13403 Berlin, Germany

Email: [email protected]

1.3. By registering for the Program, you (hereinafter — “Participant”) acknowledge that you have read and understood these Terms, accept them in full, and agree to comply with them.

1.4. The Program is available worldwide without territorial restrictions.

2. Definitions

“Loyalty Program“ or “Program“ — a customer rewards program operated by DPO Europe that provides discounts on services based on the number of completed orders.

“Participant“ — a natural person or legal entity registered in the Program.

“Loyalty Code“ — a unique personal promo code in the format DPOLP + 5 digits (e.g., DPOLP54473), assigned to the Participant upon registration.

“Order“ — a paid DPO Europe training recorded in the Organizer’s system.

“Loyalty Tier“ — the Participant’s current status within the Program, which determines the applicable discount.

“Discount“ — a percentage reduction in the cost of services granted to the Participant in accordance with their Loyalty Tier.

3. Eligibility and Registration

3.1. Any natural person who is at least 18 years of age, or a representative of a legal entity, may become a Participant.

3.2. To register for the Program, complete the registration form on the Organizer’s website:

- data-privacy-office.eu

3.3. During registration, the Participant provides the following information:

- Name and surname
- Email address
- Acceptance of these Terms

3.4. Upon registration, the Participant is automatically assigned a personal Loyalty Code.

3.5. Each Participant may have only one account in the Program. Duplicate registrations using the same email address are not permitted.

3.6. The Participant must provide accurate and up-to-date information during registration.

4. Loyalty Program: Tiers and Discounts

4.1. The Program provides three loyalty tiers determined by the total number of paid Orders:

Tier	Number of Orders	Discount
Tier 1	1 order	4%
Tier 2	2 orders	12%
Tier 3	3 or more orders	20%

4.2. The Loyalty Tier is determined automatically based on the Participant’s total number of Orders and is recalculated after each new Order.

4.3. Loyalty Tiers do not decrease. Once a tier is achieved, it is retained permanently and does not reset after purchases or due to the passage of time.

4.4. When the Loyalty Tier changes, the Participant receives an email notification with the new discount amount.

5. Application of Discounts

5.1. The Discount is applied to the cost of DPO Europe services in accordance with the Participant’s current Loyalty Tier.

5.2. The Discount applies to all training services offered by the Organizer, unless otherwise specified in the description of a particular service or promotion.

5.3. To receive the Discount, the Participant must place an Order using the email address provided during registration in the Program. The Participant is not required to present or know their Loyalty Code.

5.4. The Loyalty Program Discount can be combined with other promotional offers, promo codes, and discounts.

5.5. The Discount cannot be exchanged for a monetary equivalent.

5.6. The Loyalty Code is personal and non-transferable.

6. Communications

6.1. By registering for the Program, the Participant consents to receiving the following email communications:

- Welcome email with the Loyalty Code
- Notifications of changes to the Loyalty Tier and Discount amount
- Informational messages related to the Program

6.2. The language of communications is English.

6.3. The Participant may opt out of marketing communications by clicking the unsubscribe link in any email received. Opting out of marketing communications does not affect the receipt of transactional notifications related to the Program.

7. Data Protection

7.1. The Organizer processes the Participant’s personal data in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and applicable data protection legislation.

7.2. Data Controller: DPO Europe GmbH.

7.3. Categories of data processed:

- Name and surname
- Email address
- Registration date
- Loyalty Code
- Order history (number of orders, dates)

7.4. Purposes of processing:

- Administration of Program participation
- Calculation of Loyalty Tier and Discount
- Sending Program-related notifications

7.5. Legal basis for processing:

- Performance of a contract (Art. 6(1)(b) GDPR) — for Program administration
- Consent (Art. 6(1)(a) GDPR) — for marketing communications

7.6. Data retention period: Personal data is retained for the duration of Program participation and deleted within 90 days after the Participant leaves the Program, unless longer retention is required by law.

7.7. Data subject rights. In accordance with the GDPR, the Participant has the right to:

- Access their personal data
- Rectification of inaccurate data
- Erasure of data (“right to be forgotten”)
- Restriction of processing
- Data portability
- Object to processing
- Withdraw consent

7.8. To exercise these rights, the Participant may contact the Organizer at: [email protected].

7.9. The Participant has the right to lodge a complaint with the supervisory authority (Berliner Beauftragte für Datenschutz und Informationsfreiheit).

7.10. Detailed information about data processing is available in the Privacy Policy published on the Organizer’s websites.

8. Modification and Termination of the Program

8.1. The Organizer reserves the right to modify these Terms at any time, including discount amounts, loyalty tiers, and other Program parameters.

8.2. Participants will be notified of any changes to the Terms by email at least 30 days before the changes take effect.

8.3. Continued participation in the Program after the changes take effect constitutes the Participant’s acceptance of the updated Terms.

8.4. The Organizer may suspend or terminate the Program at any time by providing Participants with at least 30 days’ notice.

8.5. The Participant may withdraw from the Program at any time by sending a request to [email protected]. Upon withdrawal, accumulated discounts are forfeited.

8.6. The Organizer may exclude a Participant from the Program in the event of:

- Providing knowingly false information during registration
- Abuse of the Program (including sharing the Loyalty Code with third parties)
- Violation of these Terms

9. Limitation of Liability

9.1. The Loyalty Program is provided “as is“. The Organizer does not guarantee uninterrupted operation of the systems supporting the Program.

9.2. The Organizer shall not be liable for:

- Technical failures, delays in order processing, or tier assignment
- Inability to use the Discount due to reasons beyond the Organizer’s control
- Losses arising from participation in the Program or the inability to participate

9.3. The Organizer’s total aggregate liability for any claims related to the Program is limited to the amount of the Discount that should have been provided to the Participant.

9.4. These limitations do not apply to liability that cannot be limited under applicable law.

10. General Provisions

10.1. Governing law. These Terms are governed by and construed in accordance with the laws of the Federal Republic of Germany.

10.2. Jurisdiction. Disputes arising from these Terms shall be subject to the exclusive jurisdiction of the courts of Berlin, Germany.

10.3. Severability. If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

10.4. No waiver. Failure or delay in exercising any right under these Terms does not constitute a waiver of such right.

10.5. Entire agreement. These Terms constitute the entire agreement between the Participant and the Organizer with respect to participation in the Program and supersede all prior agreements on this matter.

10.6. Language. These Terms are available in Russian and English. In the event of any discrepancy, the English version shall prevail.

11. Contact Information

DPO Europe GmbH