PRIVACY NOTICE
1 Introduction
TLC Marketing Worldwide is committed to protecting the privacy and security of your personal data.
Please read this Privacy Notice and any other privacy notice or fair processing notice we may provide on specific occasions carefully, as it is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.
This Privacy Notice has been drafted is in accordance with the relevant laws of the United Kingdom but may be applied to personal information processing activities globally. The processing activities may be more limited in some jurisdictions due to the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the way we process that personal information. In those instances, we may adjust our internal policies and/or practices to adapt to the requirements of local law.
This Privacy Notice supplements the other notices and is not intended to override them.
2 Who we are.
TLC Worldwide is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the TLC Worldwide Group so when we mention " TLC Worldwide ", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the TLC Worldwide Group responsible for processing your data. TLC Marketing Worldwide Group Limited is the controller and responsible for this website.
3 Our Contact Details
4 Our Data Protection Officer (DPO)
We have appointed GRCI Law Limited as our DPO, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, our privacy practices or how we handle your personal data, please contact our DPO at dpoaas@grcilaw.com.
5 TLC Worldwide Group Companies
Companies that make up the TLC Worldwide Group are:
Registered office - TLC Marketing Worldwide, 54 Baker Street, London, W1U 7BU, United Kingdom
6 Websites
The following websites are provided by the TLC Worldwide Group
7 What is meant by personal data or personal information and Data Protection Law?
Personal data (also called personal information) is information which identifies you as an individual.
Some examples are outlined below:
In this privacy notice Data Protection Law means the applicable legislation protecting the fundamental rights and freedoms of individuals and, where required by law, legal entities, and in particular, their right to privacy with respect to the processing of personal data and which contains restrictions on the cross-border transfer of personal data, including but not limited to the EU GDPR, UK GDPR, the Brazilian Data Protection Law (LGPD), the California Privacy Rights Act (CPRA) and any national legislation supplementing the GDPR in Member States of the EEA.
8 How we get the information about you
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: Get in Touch
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Our website will prompt you with details of cookies and provide options to accept or decline.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public source as set out below:
Technical Data from the following parties:
9 What personal information we use
We may collect, use, store and transfer different kinds of personal information about you depending on our relationship with you:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in 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 notice.
10 The specific purposes of us using your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to:
11 Legal basis for processing your personal information.
We need your personal information to conduct our business and provide you with our website and services. Most commonly we will use your personal information in the following circumstances:
We will only collect, process and/or use personal information where we are satisfied that we have an appropriate legal basis to do so.
EEA and UK residents: For more information on how we use and process your information see the section called “UK and EEA residents.”
Californian residents: For more information on how we use and process your information see the section called “Californian residents”.
Canadian residents: For more information on how we use and process your information see the section called “ Canadian residents”.
Brazil: For more information on how we use and process your information see the section called “Brazil residents”.
Saudia Arabian residents: For more information on how we use and process your information see the section called “Saudia Arabian residents”.
South African residents: For more information on how we use and process your information see the section called “South African residents”.
If we collect information for one purpose and then intend to use it for a different purpose, we will seek your consent to do so and/or inform you were necessary or appropriate.
12 Automated decision making
We do not use automated decision making on our website.
13 Sharing your information
At TLC Marketing Worldwide, we understand the importance of your privacy, and we want to be transparent about how your personal information is handled. We may need to disclose your personal data to third-party organizations that assist us in various capacities related to data management and storage. These organizations include:
In addition, there are instances where we collaborate with partner organizations to provide you with a broader range of products, services, or promotions. These partners may include:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We or the third parties mentioned above occasionally also share personal data with:
We will not share your personal data with any other third party without your consent.
The specific kind of information we share will depend on your activities with us and only to the extent as required or permitted by law, and/or with your consent.
Please note however that this privacy notice does not apply to sharing of personal information by third party providers who may collect personal information from you and may share it with us. In these situations, we strongly advise you to review the applicable third-party provider’s privacy notice before submitting your personal information.
14 Safeguarding your personal information
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We will review, monitor and update these security measures to meet our business needs, changes in technology and regulatory requirements. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we do not have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many Information security risks that exist and take appropriate steps to safeguard your own information.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
15 Third-party services, websites and plugins
You should be aware that information about your use of our website (including your IP address) may be retained by your ISP (Internet Service Provider), the hosting provider or any third party that has access to your Internet traffic.
Our Websites may contain links to third-party websites and plugins, for instance a social media login plugin. If you choose to use these websites, plugins, or services, you may disclose your information to those third parties.
We are not responsible for the content or practices of those websites, plugins, or services. The collection, use and disclosure of your personal information will be subject to the privacy notices of these third parties and not this privacy notice. We urge you to read the privacy and cookie notices of the relevant third parties.
16 Transferring information overseas
We do business globally and may centralize certain aspects of our information processing activities and data storage in different countries. We may therefore have to share and transfer your personal information from one country to another, or even across multiple jurisdictions. Your personal information may therefore be subject to privacy laws that are different from those in the country where the personal information is collected or those in your country of residence.
We will ensure your personal information has an appropriate level of protection and will undertake appropriate due diligence and risk assessments prior to transferring the information. We will ensure the transfer of your personal information in line with applicable Data Protection Law. Often, this protection is set out under a contract with the organization that receives your personal information. You can find more details of the protection given to your information when it is transferred overseas by contacting us.
For residents of Saudi Arabia: - We transfer your Personal Data outside Saudi Arabia where a corresponding approval from the regulatory authority was obtained.
17 How long do we keep your personal information.
To help TLC Worldwide operate our service and meet our legal obligations we will store personal information for 90 days after the date of the product, service, or promotion for which the information was originally used. We will only hold information for a longer or shorter period when we are under a legal obligation to do so.
18 What Happens If You Don’t Provide your Information?
You may always choose what personal information (if any) you wish to provide to us. Please note, however, some of our products and services to you may be affected if you choose not to provide certain details, for example, we cannot reply to you without a name or contact details.
We also need your personal information to be able to assess your application for our vacant job roles.
19 Opting out of Marketing
If you provide us with your contact details (e.g., email address), we may contact you to let you know about the products, services, promotions, and events offered that we think you may be interested in.
You can unsubscribe from our marketing and promotional communications by clicking on the unsubscribe link in the emails or by contacting us at privacy@tlcworldwide.com
You will then be removed from the marketing list; however, we may still communicate with you for example to send you service-related messages that are necessary to respond to your requests or for other non-marketing related purposes.
20 Cookies and other tracking technologies
Each time you interact with our website, we may, depending on the consent provided and your jurisdiction, automatically collect personal information, including technical data about your device, your browsing actions and patterns, content, and usage data. We collect this data using Cookies, server logs and other similar technologies like pixels, tags, and other identifiers in order to remember your preferences, to understand how our website is used, and to customize our marketing offerings.
21 What are your Rights?
In some regions such as Brazil, Canada, the EEA, and UK you have rights that allow you greater control of and access to your personal information.
These rights may include the right:
In certain circumstances you may also have the right to object to the processing of your personal data. You can make a request to exercise your rights by contacting us at privacy@tlcworldwide.com.
We will consider and act upon any requests in accordance with applicable data protection laws.
22 Questions or Concerns
If you have any questions, concerns, or complaints about this Privacy Notice, or our privacy practices in general, please email us at privacy@tlcworldwide.com.
23 Further information for EEA and UK residents
We are subject to the UK General Data Protection Regulation (UK GDPR) and the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the UK and European Economic Area (EEA).
(a) Details about our processing of your personal information
The table below describes the ways we plan to use your personal data, and which Lawful Basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| LAWFUL BASIS | PURPOSE EXAMPLES |
Contract We use your personal information on the basis that it is necessary for us evaluate applications and candidates for a vacant role prior to entering into an employment contract for that role with the most suitable candidate.
| Recruitment of candidates (contractors, employees and providers) We will use the personal information we collect about you to assess your skills, qualifications, and suitability for the role for which you applied. We may use the following personal data:
|
Legitimate interest
When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law. | Managing our business We process Personal Data for our own legitimate business interest. This relates to us managing our business to enable us to maintain and monitor the performance of our website and to constantly look to improve the website and the services it offers to our users, including when we respond to your queries and complaints, where you are not a client or supplier, or a potential client or supplier. We may use the following personal data:
Provide and maintain our websites. To provide and maintain our website, including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website We may use the following personal data:
Recommendations and marketing
To make recommendations to you about services that may interest you. We may use the following personal data:
To measure and analyse the effectiveness of the advertising we serve you. We may use the following personal data:
To make suggestions and recommendations to you about goods or services that may be of interest to you and necessary for our legitimate interests (to develop our products/services and grow our business). We may use the following personal data:
Rights and claims
To enforce or apply our website terms of use, our policy terms and conditions, or other contracts. To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with. We may use the following personal data:
Data subject rights Verifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests. We may use the following personal data:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise.
|
Legal obligations
We may use your Personal Data to comply with laws (for example, if we are required to co-operate with a police investigation after a court order orders us to).
| Legal requirement
The processing is necessary for compliance with legal obligations, such as but not limited security requirements.
To comply with applicable law, for example in response to a request from a court or regulatory body, where such request is made in accordance with the law.
Criminal activity
To detect fraudulent or criminal activity, we may share information with forces such as the police. |
Consent
We may have to get your consent to use your Personal Data, such about you or when we want to send you marketing.
Wherever consent is the only reason for using your Personal Data, you have the right to change your mind and/or withdraw your consent at any time by clicking the Unsubscribe button at the bottom of an applicable email or by contacting us. | Marketing To measure and analyse the effectiveness of the advertising we serve you.
We may collect IP addresses and store Cookies on visitors’ devices.
We may use the following personal data, depending on what you consent to:
Data analytics We use data analytics to improve our website, products/services, marketing, customer relationships and experiences. We may use the following personal data:
|
(b) Details about sharing
More details about who we share your personal data with and why are set out in the table below. In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.
To exercise your rights or get more information about exercising them, please contact us at, privacy@tlcworldwide.com giving us enough information to identify you
(c) Details about Data Transfers overseas
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA, we do so on the basis of an adequacy decision or (where this is not available) legally approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so based on an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
(d) Your Rights
Please see more details about your rights in the table below. In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.
YOUR RIGHT | DETAILS |
|---|---|
| Right to be informed | We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information. |
| Right of access | You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information. When you request this data, this is known as making a data subject access request (DSAR). In most cases, this will be free of charge; however, in some limited circumstances, for example repeated requests for further copies, we may apply an administration fee.
|
| Right to rectification | You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. |
| Right to erasure | You have the right to ask us to erase your personal information in certain circumstances. We have the right to refuse to comply with a request for erasure if we are processing the Personal Data for one of the following reasons:
· To exercise the right of freedom of expression and information. · To comply with a legal obligation. · To perform a task in the public interest or exercise official authority. · For archiving purposes in the public interest, scientific research, historical research or statistical purposes. · For the exercise or defence of legal claims.
|
| Right to restriction of processing | You may ask us to stop processing your Personal Data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:
|
| Right to object to processing | You have the right to object to processing in certain circumstances. You can also object if the processing is for a task carried out in the public interest, the exercise of official authority vested in you, or your legitimate interests (or those of a third party).
|
Right to data portability
| This right only applies if we are processing information based on your consent or for the performance of a contract and the processing is automated.
|
(e) Complaints
We hope that we can resolve any query or concern you raise about our use of your information. Please contact us at privacy@tlcworldwide.com first and title your email “Complaint”. All complaints will be treated in a confidential manner, and we will try our best to deal with your concerns.
You have the right to lodge a complaint with a supervisory authority in the EEA member state where you work or normally live, or where any alleged infringement of Data Protection Law occurred.
The details of European supervisory authorities can be found here: Our Members | European Data Protection Board (europa.eu)
The supervisory authority in the UK is the ICO, which may be contacted at https://ico.org.uk/concerns or by telephone on 0303 123 1113.
The details of the supervisory authority in Switzerland can be found here: Startseite (admin.ch)
24 Further information for Brazilian residents
(f) Lawful Basis of Processing
Article 7 of the LGPD sets out 10 legal grounds for data processing. You can't collect personal data unless you can justify it under one of these grounds:
Only use your personal information when the law allows us to. This means we Must have one or more legal basis to use your personal information. Most of these will be self-explanatory. The most common legal basis which will apply to our use of your personal information or set out below:
(g) Legitimate Interests Details
Legitimate interest When we rely on this, we will carry out a Legitimate Interests Assessment to ensure we consider and balance any potential impact on you (both positive and negative), and your rights under Data Protection Law. | Managing our business We process Personal Data for our own legitimate business interest. This relates to us managing our business to enable us to maintain and monitor the performance of our website and to constantly look to improve the website and the services it offers to our users, including when we respond to your queries and complaints, where you are not a client or supplier, or a potential client or supplier. We may use the following personal data:
Provide and maintain our websites. To provide and maintain our website, including to monitor the usage of these, troubleshooting, data analysis, network security and system testing necessary for our legitimate interests in maintaining the useability, security and integrity of our website. We may use the following personal data:
Recommendations and marketing To make recommendations to you about services that may interest you. We may use the following personal data:
To measure and analyse the effectiveness of the advertising we serve you. We may use the following personal data:
To make suggestions and recommendations to you about goods or services that may be of interest to you and necessary for our legitimate interests (to develop our products/services and grow our business). We may use the following personal: data:
Rights and claims To enforce or apply our Website terms of use, our policy terms and conditions, or other contracts. To exercise our rights, to defend ourselves from claims and to keep to laws and regulations that apply to us and the third parties we work with. We may use the following personal data:
Data subject rights Verifying your identity when you exercise your data subject rights. Fulfilling data subject rights requests. We may use the following personal data:
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise.
|
(h) Details about sharing
More details about who we share your personal data with and why are set out in the table below. In most circumstances, you do not need to pay any charge for exercising your rights. We have one month to respond to you.
To exercise your rights or get more information about exercising them, please contact us at, privacy@tlcworldwide.com. giving us enough information to identify you.
The transfer of personal data to other jurisdictions is allowed only subject to compliance with the requirements of the LGPD. Prior specific and informed consent is needed for such transfer, unless:
(i) Data Transfers out of Brazil
We will only transfer personal data to other countries where allowed to do so by the LGPD where:
(i) Specific contractual clauses for a given transfer
(ii) Standard contractual clauses
(iii) Global corporate norms, or
(iv) Regularly issued stamps, certificates and codes of conduct
(j) Rights of Brazilian Residents
That said, you may exercise to protect your personal data. You may access those rights at anytime by contacting us at privacy@tlcworldwide.com.
You have several rights under Data Protection Law (Brazilian Data Protection Law (LGPD) (As amended by Law No. 13,853/2019) including (but not limited to);
(k) Details of the Data Protection Authority of Brazil
National Data Protection Authority (ANPD) https://www.gov.br/anpd/pt-br
25 Further information for Californian residents
(l) Rights of California Residents
We do not sell your personal information.
Under California’s “Shine the Light” law, website visitors who are California residents may request and obtain a notice once a year about the personal information we share with other businesses for their direct marketing purposes. Such a notice includes a list of the categories of personal information that was shared (if any), and the names and addresses of all third parties with which the personal information was shared (if any). The notice covers the preceding calendar year. To obtain such a notice, please contact us as previously described.
Verified California residents have the right to:
For purposes of the CCPA personal information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
In order to make a request for disclosure California residents may contact us at privacy@tlcworldwide.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose.
For requests for deletion of your information please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
We will not discriminate against you as a result of your exercise of any of these rights.
In addition, under this law you are entitled to be advised how our site handles “do not track” browser signals. We do not use technology recognising do-not-track signals from your browser.
26 Further information for Canadian residents
We may process your information if you have given us specific permission (express consent) to do use your information for a specific purpose, or in situations where your permission may be inferred (implicit consent), You can with draw your consent at any time by emailing us at privacy@tlcworldwide.com
In some exceptional instances we may be able to process your information without your consent:
27 Further information for Saudi Arabian residents
For any of the purposes of the processing, the legal basis for the processing of your Personal Data will always be your implicit or explicit consent unless the personal information we collect and process from you:
28 Contact Information, Notifications, and Updates
If you have any concerns regarding privacy at TLC Marketing Worldwide or wish to contact one of our data controllers, please reach out to us with a comprehensive description of your issue to Get in touch, and we will endeavor to address it promptly. Additionally, you may contact the Data Protection Officer for the data controllers at privacy@tlcworldwide.com.
Our business is subject to continuous evolution, and as a result, our Privacy Notice may undergo periodic updates. We encourage you to visit our website regularly to stay informed about recent changes. Unless otherwise specified, our current Privacy Notice applies to all the information we hold about you and your account. We are committed to upholding the assurances we provide and will not make material alterations to our policies and practices that would diminish the protection of customer information collected in the past without the consent of the affected customers, in accordance with data regulations.
29 Revision history
Revision | Date | Record of changes | Approved by |
1.0 | 10/07/2023 | Initial version | GRCI Law, DPO |
2.0 | 12/09/2023 | Update in the Policy | GRCI Law, DPO |
This Privacy Policy describes how The Reward Company, Inc. d/b/a TLC Marketing ("TLC Marketing") collects, uses and discloses personally identifiable information. This Privacy Policy relates to our use of any personal information you provide to us via websites, phone, email and post. All websites controlled by TLC Marketing where this privacy policy is posted or referenced (collectively, the "Sites") are covered by this policy.
By using or accessing the Sites, or by otherwise choosing to submit Personally Identifiable Information to us, you signify your consent to all of the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you may not use the Sites or submit any Personally Identifiable Information to us.
This Privacy Policy includes the following sections. You should read the entire policy.
Information Collected. The Personally Identifiable Information we collect depends on how you interact with us. We may collect information such as name, email address, mailing address, phone number, date of birth and the receipts you provide. We may also collect technological information such as IP address, browser type, pages viewed, pin codes, and cookies.
Use of Information. We use the Personally Identifiable Information we collect to fulfill and administer reward requests, provide you with information, to ensure our Sites are relevant and to restrict access to some areas of the Sites, to protect against fraud, and to contact you.
Sharing and Disclosure of Information. We may disclose Personally Identifiable Information if required or permitted by law, to protect our rights, or those of our users. We may disclose information to services providers who help us process it. We may also disclose information in the context of a business transaction.
International Transfer of Information. We may transfer Personally Identifiable Information to other countries. As a result, such information may be accessed by law enforcement and governments in those countries.
Retention of Data. We store Personally Identifiable Information for the duration of the campaign you enter, and for as long as needed for the other purposes for which we process it.
Opt-Out. You can opt-out of our commercial email.
Cookies. When you visit our Site, we may use technology such as cookies, to remember your preferences, improve the efficiency of the Site, and better understand how the Site is used. You can reject cookies, but the Site may not work as well.
Changes to this Privacy Policy. We may change this policy.
Security. We take technological, physical and organizational steps to protect Personally Identifiable Information. However, information cannot be 100% secure, and we cannot promise absolute security.
Canadian Privacy Rights. Residents of Canada have an ability to access and correct their Personally Identifiable Information.
Third Party Sites. This Site may link to other websites we do not control. We are not responsible for such websites or their privacy practices.
Contacting TLC Marketing. You can contact us at support@tlcmarketing.zendesk.com.
1 Information Collected
We collect two types of information from visitors to the Sites and participants in promotional campaigns:
Personally Identifiable Information
Technological Information
1.1 Personally Identifiable Information
"Personally Identifiable Information" is information that identifies you, such as your name, address, telephone number, email address, or company name. TLC Marketing may collect and store the Personally Identifiable Information that you have provided to us. Here are some examples of manners in which we may collect your Personally Identifiable Information:
We may collect your name, email address, mailing address, phone number, and the receipts you provide, and additional information contained in an online form on the Sites to us if you participate in a promotional campaign
We may collect your name, email address, mailing address, phone number, and the receipts you provide, and additional information contained in a printed form and posted to us if you participate in a promotional campaign
We may collect your name, email address, phone number and additional information if you contact us with a question related to our services or promotional campaigns
We may collect date of birth if you participate in a campaign where there are age restrictions on participation or a prize draw
The above list is not exhaustive but provides examples of the Personally Identifiable Information that may be collected. If you do not want TLC Marketing to collect your Personally Identifiable Information, please do not provide it to us. If you have already provided us with your Personally Identifiable Information, please contact us via email on support@tlcmarketing.zendesk.com and request a deletion of your record.
1.2 Technological Information
"Technological Information" is information we collect through the use of technology on our Sites, including through our use of cookies and related technologies. Some examples of the Technological Information that is collected via our Sites are:
Internet Protocol (IP) address. Your IP address is the address used to locate your computer on the Internet
Internet Browser type (Internet Explorer, Firefox, Safari, etc.)
Statistics on page views
Pin code that provides access to participate in a promotional campaign
Cookies
We collect the above Technological Information from all visitors to our Sites. For more information on our use of cookies, please see section 7 below. If you do not want us to collect this data, please do not visit our sites and remove all cookies from your preferred web browser. Further details on removing Cookies is available on www.aboutcookies.org.
2 Use of Information
2.1 Personally Identifiable Information
We use your Personally Identifiable Information that is collected primarily for the following:
We may use Personally Identifiable Information to produce anonymous non-identifiable information, and to use or disclose such non-identifiable information in any manner we deem appropriate
2.2 Technological Information
Technological Information is used as described above, in section 7, Cookies, below, and in other ways as permitted by applicable laws, including combining Technological Information with Personally Identifiable Information. Where such information is combined with Personally Identifiable Information, we treat it as Personally Identifiable Information, and use and disclose it as described in this Privacy Policy.
3 Sharing and Disclosure of Information
3.1 Personally Identifiable Information
We may share or disclose your Personally Identifiable Information in the following instances:
To comply with the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of TLC Marketing. or act in urgent circumstances to protect the personal safety of our end users.
We may retain service providers to perform functions on our behalf, including those practices described in this Privacy Policy. When we disclose information to service providers, the service provider will have access to that information necessary to permit the service provider to perform its function.
To provide you with information, products or services that you request from us, or which we feel may interest you, where you have consented to be contacted for such purposes.
We reserve the right to transfer any Personally Identifiable Information we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed.
3.2 Technological Information
We may share Technological Information and other non-identifiable information, with third parties.
4 International Transfer of Information
If you provide us with Personally Identifiable Information, TLC Marketing may transfer that information to other group companies or affiliates or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from a country outside the UK, please note that you are transferring your Personally Identifiable Information to the UK, Brazil, France, Germany, Italy, Portugal, Spain, South Africa Some Personally Identifiable Information collected by TLC Marketing may therefore be retained in countries other than your country where privacy laws may offer different levels of protection. Personally Identifiable Information may be subject to access by and disclosure to governments and law enforcement agencies in those jurisdictions.
By providing your Personally Identifiable Information you consent to:
The use of your Personally Identifiable Information for the uses identified above in accordance with this privacy policy.
The transfer of your Personally Identifiable Information to the UK and other countries as indicated above.
5 Retention of Data
If you provide information as part of a promotional campaign your Personally Identifiable Information will normally be stored in database for the duration of the campaign.
Data and records will not be kept for longer than is necessary for the purposes for which the data was collected or used.
6 Opt-Out
We generally communicate with users who subscribe to our services via email. Although you may opt out of marketing messages, please note that it is in your interest to ensure that we are able to deliver certain non-marketing related messages and that we may be required to deliver certain notices to you by law.
We will provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites. The opt-out choice may be exercised by ticking or un-ticking the appropriate box provided at the points where Personally Identifiable Information is collected, or by contacting us using the contact details provided at support@tlcmarketing.zendesk.com.
7 Cookies
7.1 What are Cookies?
Cookies are small text files placed on your computer or mobile device by websites. They store preferences and other information to allow you to use the website efficiently and also provide information on how websites are used. Some cookies are essential for the website to function, others are optional.
With most Internet Browsers, you can erase Cookies from your computer hard drive, block all Cookies, or receive a warning before a Cookie is stored. Further details on removing Cookies is available on www.aboutcookies.org. Please note that removing or blocking Cookies may interfere with your full use of our Sites
7.2 Essential Cookies
We use session cookies to store information that are essential for the website to function. This includes cookies that store code validation and reward information. These cookies expire when you terminate your browser session.
7.3 Performance Cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is used to improve how a website works.
We use cookies to "remember" what interactions the user has had with the site and the web pages the user has viewed, for example the URL of the page.
7. 4 Which first party cookies does this site use?
Cookie | Name | Purpose | Expiry |
|---|---|---|---|
| THE REWARD COMPANY, Inc. d/b/a TLC Marketing Worldwide Temporary .NET Sessions State | ASP.NET_SessionId | Used to maintain an anonymized user session by our web servers. When you leave the site, this cookie will be removed. |
On close of current web session |
| THE REWARD COMPANY, Inc. d/b/a TLC Marketing Worldwide Persistent Cookie Consent pop up | CC_analytics | Cookie Consent cookies which appear after you have clicked on the ‘allow cookies’ in the floating footer. More info http://silktide.com/cookieconsent |
1 year from creation |
Cookie | Name | Purpose | Expiry |
|---|---|---|---|
| These cookies are used to collect information about how visitors use a THE REWARD COMPANY, Inc. d/b/a TLC Marketing Worldwide site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. | |||
| GoogleAnalytics | _utma | Google stores the information collected by the cookies on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. Unless you opt-out of the Google Cookie, by using this site you consent to the use of the Google Cookie and any information generated by Google Analytics. | 2 years |
| _utmb | 30 minutes | ||
| _utmc | On close of web session | ||
| _utmz | 6 months | ||
| You can find an overview of privacy at Google here. For information on how to opt-out from all Google Analytics cookies (from all sites not just from THE REWARD COMPANY, Inc. d/b/a TLC Marketing Worldwide visit Google. | |||
The above list is not exhaustive and comprises the standard set of Cookies used by THE REWARD COMPANY, Inc. d/b/a TLC Marketing Worldwide when building a site.
If you would like more information on the Cookies used by our site (and any other site) you can do so from within your web browser by following these steps: http://www.wikihow.com/View-Cookies
8 Changes to this Privacy Policy
We reserve the right to change this privacy policy from time to time in our sole discretion. When we do, we will also revise the "Last Updated" date at the bottom of this privacy policy.
9 Security
Data transmissions over the Internet cannot be guaranteed to be 100% secure. However, we take steps including technological, physical and organizational measures, to help ensure security of our systems and protection of the data. Personally Identifiable Information may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by applicable laws. Personally Identifiable Information we collect is managed from our offices at 19 Harcourt Street, London, W1H 4HFIf we learn of a security systems breach we may attempt to notify you in accordance with the applicable law so that you can take appropriate protective steps. By using these Sites or providing Personally Identifiable Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs or we may send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
10 Canadian Privacy Rights
If you are a resident of Canada, you have a right to request access to your Personally Identifiable Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personally Identifiable Information to TLC Marketing and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below. We will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain Personally Identifiable Information in certain circumstances, for example if it contains Personally Identifiable Information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personally Identifiable Information. We may require you to verify your identity before you access your Personally Identifiable Information.
11 Third Party Sites
Our site may contain links to websites owned by third parties. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from this site to other websites, or references to products, services or publications other than those of TLC Marketing do not imply the endorsement or approval of such websites, products, services or publications by TLC Marketing.
12 Contacting TLC Marketing
Please address requests for information or questions regarding this Privacy Policy to:
The Data Protection Officer
The Rewards Company, Inc. d/b/a TLC Marketing.
19 Harcourt Street
London
W1H 4HF
support@tlcmarketing.zendesk.com
Terms of website use
This page (together with the documents referred to on it) tells you the terms of use on which you may make use of our website Enter Microsite URL(our site), whether as a guest or a registered user. Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, you may not use our site.
Information about us
AleveXrewards.com is a site operated by The Reward Company, Inc. d/b/a TLC Marketing. Our group trading address is 19 Harcourt Street, London, W1H 4HF.
Accessing our site
Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice. We will not be liable if for any reason our site is unavailable at any time or for any period. From time to time, we may restrict access to some parts of our site, or our entire site, to users who have registered with us.
If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. You are responsible for any actions or activities which take place under your identification code, password or any other piece of information. In the event that your identification code, password or any other piece of information is used without your consent or that you discover any other breach of security, you agree to promptly notify us using the information provided below. We are not responsible for your failure to comply with this clause, or for any delay in shutting down your access after you have reported a breach of security to us. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use. You are responsible for making all arrangements necessary for you to have access to our site, including any costs you incur for internet or data charges. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms, and that they comply with them.
Intellectual property rights
We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it other than any third party intellectual property rights. All of the works and materials on the site are protected by copyright laws, trademark laws and treaties around the world. All such rights are reserved.
The trademarks, logos, and service marks (collectively the “Trademarks”) displayed on this site are our registered and unregistered Trademarks other than any third party intellectual property rights. In addition, page headers, graphics, icons and scripts are our service marks and our protected intellectual property and may not be copied, used or imitated without the prior written consent of TLC Marketing. Nothing contained on this site should be construed as granting, by implication, or otherwise, any license or right to use any Trademark displayed on this site or those of any third party without our express written permission. Your misuse of the Trademarks displayed on this site, or any other content on this site is strictly prohibited. You may print off copies, and may download extracts, of any page(s) from our site for your personal reference and you may draw the attention of others within your organization to material posted on our site.
Without limiting the foregoing, you must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. You may not otherwise reproduce, modify, copy or distribute or use for commercial purposes any of the materials or contents of our site without our permission. Our status (and that of any identified contributors) as the authors of material on our site and the owners of the Trademarks on our site must always be acknowledged. If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.
You are also advised that we will enforce our intellectual property rights to the fullest extent permitted by the law.
Reliance on information posted
Any information, commentary and other materials posted on our site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our site, or by anyone who may be informed of any of its contents.
Our site includes links to other web sites or material which are beyond our control. We are not responsible for content on the Internet or World Wide Web pages or any other site outside our site, even if we provide a link to them.
Promotional Campaigns
Our site allows you to fulfill reward requests from promotional campaigns for which you qualify. Promotional campaigns may be subject to terms and conditions that apply in addition to these website Terms of Use. By participating in any such promotional campaign, you agree to the terms that apply to it.
Our site changes regularly
We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site or any portion of it, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.
Our liability
The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. You must bear the risks associated with the use of the internet.
To the fullest extent permitted by law, we and third parties connected to us hereby expressly exclude:
All conditions, representations, warranties and other terms of any kind which might otherwise be implied by statute, common law or the law of equity, and whether express or implied.
Incompatibility of our site with any of your computer equipment, software or telecommunications links.
Unsuitability, unreliability or inaccuracy of our site, including without limitation any material or information on our site.
To the fullest extent permitted by law you acknowledge and agree that we will not be liable to you or any third party for any consequential or incidental damages (including but not limited to loss of income or revenue, loss of business, loss of profits or contracts, loss of anticipated savings, loss of data, loss of goodwill, wasted management or office time and/or any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable). You expressly acknowledge that we have entered into this agreement with you and makes the site available to you, in reliance upon the limitations and exclusions of liability and the disclaimers set forth herein, and that the same form an essential basis of the bargain between you and us. You expressly agree that the limitations and exclusions of liability and the disclaimers set forth herein will survive, and continue to apply in the case of a fundamental breach or breaches, the failure of essential purpose of contract, the failure of any exclusive remedy, or termination of this agreement. This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law. Nothing in these terms shall affect the statutory rights of a consumer where those rights may not be affected under the applicable law.
Comments or opinions expressed on the services are those of their respective users only. The views expressed on the services and in user content do not necessarily represent or reflect our views. We are not responsible for, and disclaim all liability in relation to, the user content posted, uploaded or otherwise submitted to or through the site.
Any promotions, products and/or services described on the site are offered in jurisdictions where they may be legally offered. The information on the site is not an offer or solicitation by anyone in anyone in any jurisdiction in which an offer or solicitation cannot legally be made, or to any person to whom it is unlawful to make a solicitation.
Indemnity
You agree to indemnify and hold us harmless from all liabilities, claims and expenses that arise out of the content you submit, post or transmit via our site, or from your use/misuse of our site or the use/misuse by any person for whom you are responsible or from your violation of these terms.
Information about you and your visits to our site
We process information about you in accordance with our privacy policy. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.
Uploading material to our site
Any material you upload to our site will be considered non-confidential and non-proprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. To this end, by uploading or submitting any material to our site, you: i) grant us a world-wide, perpetual, irrevocable, transferable, sub-licensable, royalty-free, non-exclusive, and unrestricted license to copy, reproduce, adapt, transmit, edit, modify, or otherwise use, publicly display, distribute, translate and create compilations and derivative works from, any and all content you submit (in any format or media) to or through, the site; and (ii) waive all moral rights in and to all content that you submit to or through the site in favour of us. For greater certainty, this means that, among other things, we have the right to use any and all ideas you submit (including ideas about our products, services, publications or advertising campaigns) in any manner that we choose, without any notice or obligation to you whatsoever. We do not generally screen or edit content submitted by users, but that we reserve the right, in our sole and absolute discretion and at any time, although we are under no legal obligation to do so, to monitor, edit or otherwise remove, without any notice and without obligation or incurring any liability, any content on the Site.
We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy. If you believe there is infringing content on our site, you may contact us using the contact information below.
You are prohibited from posting or transmitting any unlawful, threatening, libellous, defamatory, obscene, pornographic or profane material or any material that would constitute or encourage conduct that would be considered unlawful and/or a criminal offence.
We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our site.
Viruses, hacking and other offences
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack or any other form of attack.
We will report any breach of this provision to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.
Linking to our site
You may not link to our home page or other portions of our site without our express written consent. Our site must not be framed on any other site, nor may you create a link to any part of our site without our prior written consent. We reserve the right to withdraw any linking permission without notice.
If you wish to make any use of material on our site other than that set out above, please address your request to support@tlcmarketing.zendesk.com.
Links from our site
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.
Variations
We may revise all or any part of these terms of use at any time by amending this page without incurring any liability or obligation whatsoever to you or any other person or entity. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site.
Where required by applicable law, we will notify you of any changes to these terms of use by notice on this website at least thirty (30) days before the modification comes into effect. In addition, where required by law or at our discretion, we will provide you notice using email and/or your mailing address, or any other contact information we have for you in our discretion. Where required by law or at our discretion, this notice will be provided at least thirty (30) days before the change comes into effect (or such longer period as may be required by applicable law) and will as required by law set out the new clause, or the modified clause and how it read formerly, and the date on which the change will come into effect. Before the change comes into effect, you may cancel this agreement rather than accept the change. To the fullest extent permitted by law, as your sole remedy and where required by law, you may refuse the modification and rescind, or cancel the this agreement without cost, penalty, cancellation fee or cancellation indemnity, by providing us with notice to that effect no later than thirty (30) days after the modification comes into force, using the information in the notice, if the change results in increased obligations to you or a reduction of obligations on us. To the fullest extent permitted by applicable law, your continued access to and/or use of our site, after the date specified in such notice constitutes your full acceptance of, and agreement to be legally bound by, these Terms of Use, as modified.
IF YOU DO NOT ACCEPT AND AGREE TO BE LEGALLY BOUND BY AND COMPLY WITH THESE TERMS OF USE, YOU ARE NOT PERMITTED TO ACCESS OR USE THE SITE.
Your concerns
If you have any concerns about material which appears on our site, please contact support@tlcmarketing.zendesk.com or write to us at 19 Harcourt Street, London, W1H 4HF.
Jurisdiction and applicable law
For users who are not individuals residing in the province of Quebec, these terms of use are governed and construed in accordance with the law of the State of New York and any Federal laws of the United States applicable therein (without giving effect to their conflicts of law principles) and any disputes will be decided only by the State and Federal courts located in New York City, New York. Thank you for visiting our site.
General
If any provision of these Terms of Use is held invalid or unenforceable by any court having competent jurisdiction, such provision shall be enforced to the maximum extent permitted by law, and the remaining provisions of these Terms of Use shall continue in full force and effect. No failure to exercise or waiver of any provision of these Terms of Use shall be deemed a further or continuing waiver of such provision or any other provision of these Terms of Use.
We may assign our rights and obligations under these Terms of Use, in whole or in part, to any party at any time without any notice. These Terms of Use may not be assigned by you, and you may not delegate your duties under them, without our prior written consent.
These Terms of Use are binding upon you, your heirs, executors, beneficiaries, successors and assigns and you may not assign this agreement to any other party without our prior written consent, which consent may be withheld in our sole and absolute discretion.
Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). We have collected the following categories of personal information from consumers within the last twelve (12) months:
| Categories | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Public information does not include:
Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from our you.
Indirectly from you. For example, through information we collect from our clients in the course of providing services to them.
Directly and indirectly from activity on our website.
From third-parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided.
To provide you with information, products or services that you request from us.
To provide you with email alerts.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To improve our website and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
Our affiliates.
Service providers.
Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Third party marketers who we feel you will benefit from their services.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Calling us at +44 20 7725 6000
By writing us at: 19 Harcourt Street, London, W1H 4HF
By email us at: support@tlcmarketing.zendesk.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +44 20 7725 6000
Website: https://www.tlcmarketing.com/
Email: support@tlcmarketing.zendesk.com
Postal Address:
Attn: TLC Marketing
19 Harcourt Street, London, W1H 4HF
*Must be a Gap Inc. credit card holder who received a promotional communication from Athleta and make a qualifying purchase between 10/15/2024 – 11/15/2024 to receive a reward. Must spend $150 or more with your Gap Inc. credit card in a single transaction (after discounts and before taxes in participating Athleta stores or on Athleta.com to qualify. Offer not valid for previously purchased merchandise or gift cards. Offer only available while supplies last. Valid in U.S. only. Must be 18+ years old. Limit 1 reward per customer. Receipt with qualifying purchase and application form must be submitted on www.AthletaTravelReward.com within fourteen (14) days of purchase to receive $150 Travel Savings Credit. Receipt must be legible. Final day to submit is 11/29/2024. Reward is Non-Transferable and has no cash value. $150 Travel Savings Credit is only redeemable on AthletaReward.travelleisureclub.com. Full value of the reward may not be able to be applied in one transaction. No refunds or replacements of the reward. Valid Credit card required when using the Reward. $150 Travel Savings Credit must be redeemed by 2/1/2025. Travel Leisure Club terms and conditions apply here. Full promo terms and conditions apply here. Void where prohibited.
Questions? Reach out to us at Athletarewards@tlcrewards.com and we will be happy to assist you.