{"page":"/blog/loyalty-data-advertising-consent","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Use","What happens to member data","What leaves the program owner","Typical legal trigger"],"rows":[["1. Own marketing on owned channels","Owner targets members with its own offers in its app, site or email","Nothing","Privacy notice; email and SMS marketing rules; GDPR basis in the EU and UK"],["2. Onsite ads for other brands","Owner selects members to see a brand's ad on the owner's surfaces","An aggregate report to the brand","Disclosure to the brand is avoided; profiling notice and opt-outs still apply"],["3. Offsite audiences","Owner sends a segment to another platform to show ads elsewhere","A segment ID, or member identifiers such as hashed emails","Often \"sale\" or \"sharing\" under US state law; GDPR basis and device consent in the EU and UK"],["4. Data collaboration","Owner and brand compare customers in a clean room","Aggregate overlap and lift results","Depends on whether row-level data reaches the brand; contracts and controller roles"],["5. Card-linked or merchant-funded offers","Brand funds a reward; owner matches purchases","Redemption counts and sales reports","Financial privacy rules if the owner is a bank; incentive rules if it is a retailer"]],"sourceUrls":[[],[],[],[],[]]}