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Comment by hkh28

> You might need to retain some data for potential future refunds, for example.

Then that would be a legitimate interest, and you could store that information for a period of time that is reasonable for processing refund requests.

But you would be barred from using that same information for a different purpose, e.g. the loyalty program.

GDPR article 25 requires systems to be have privacy built in, so a system such as the one you describe where a separation of these concerns is impossible, would probably itself be in violation of the regulation.

parent hkh28 5 years ago

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