TLC DigiTech Private Limited which includes group companies and their affiliates Goodtimes Marketing Pvt. Ltd, SLS Software Pvt. Ltd, TLC EMarketing Pvt. Ltd, TLC International Limited, Nairobi Kenya and TLC International W.L.L. Bahrain (hereinafter referred to as “TLC”), recognizes that privacy is important to its customers. We are transparent about how we collect, store, use and disclose data and make it easier for you (the “User”) to understand and exercise choices available to you in this regard.
This privacy policy (“Privacy Policy”) describes the privacy practices of TLC for the data that we collect:
Collectively, we refer to the Websites, the Apps, Digital Campaigns, Tech Products, Tech Platforms and our Social Media Pages, as “Online Services” and, together with offline channels, the “Services” By using the Services, you agree to the terms and conditions of this Privacy Policy.
The User must carefully read this Privacy Policy, which has been written clearly and simply, to facilitate its understanding, and to freely and voluntarily determine whether he/she wishes to provide their Personal Data, or that of third parties, to TLC, its group companies and their affiliates.
If you fail to provide certain information when requested or withdraw the consent of use of your Personal Data or provide us incomplete or inaccurate information, we may not be able to perform the contract we or our partners/clients have entered into with you, and we may also be prevented from complying with our own legal obligations.
IDENTIFICATION: WHO WE ARE & WHAT WE DO
NAME OF THE COMPANY: TLC DigiTech Private Limited
REGISTERED OFFICE: 501, Salcon Aurum, Jasola District Centre, New Delhi-110 025, India
EMAIL: contactus@tlcgroup.com
DATA PRIVACY OFFICER (DPO): Abdul Majid, Contact: privacyofficer@tlcgroup.com
TLC is in the business of inter alia, marketing and managing loyalty memberships for its clients and partners and providing other technology solutions (such as food delivery, table reservations, experience vouchers, etc.) through its Tech Products and Tech Platforms to its clients, customers and partners in the hospitality industry. Details of its various services and clients are available on www.tlcgroup.com. It has its own proprietary software, Tech Platforms and Apps to provide such products and services to its clients, customers and partners.
The information provided by User to TLC can be shared with the hotels, hotel companies, restaurant partners, and/or similar businesses or third parties whose products, services and/or membership programs are offered to you, each in relation to and for the purpose of facilitating fulfilment of the commitments made to you by the hotel, hotel companies, restaurant partners and/or similar businesses.
This data is also collected for the purposes of enrolling members and providing services in respect of loyalty membership programs managed by TLC in conformity with the respective privacy policy of TLC and such hotels and program partners.
This Privacy Policy describes how TLC protects your privacy when TLC receives User information from the various channels as mentioned above. This Policy may be supplemented or amended from time to time to inter-alia reflect changes in the law, our data collection and use practices, the features of our services, or advances in technology.
Use of information we collect is subject to the Privacy Policy in effect at the time such information is used. By using our Tech Platforms, Tech Products or other Services and/or providing us with your information as described above, you are expressly agreeing to our terms and conditions, including the terms of this Privacy Policy. If you do not consent to the collection, use, disclosure and transfer of your information as described in this Privacy Policy, you may choose to cease availing our Services and not provide us the information as described above.
You have the right to withdraw your consent at any time while utilizing the Tech Platforms, Tech Products and/or any other Services. In case you decide to withdraw your consent or request your data to be erased from our system, at any time while utilizing our Tech Platforms, Tech Products and/or other Services, you should e-mail us at contactus@tlcgroup.com, following which we will delete all your Personal Data from our systems subject to any mandatory retention requirements under applicable laws, and have the right to stop providing you the Services for which the said information was sought.
As used in this Privacy Policy, the term “Personal Data” means personal information that identifies you personally, either alone or in combination with other information provided by you and now available with us. This information that we collect directly from you typically includes your name, mailing address, telephone numbers, e-mail address and other information needed to provide our Services effectively. We use your Personal Data to administer the loyalty programs we manage, manage and operate our Tech Platforms, Tech Products and other Services; and respond to your queries and communicate with you about related offers, transactions and ancillary services. The personal information/data you provide directly to us could include the following with several fields being optional which are clearly communicated as ‘optional’ depending on the Service availed.
There are other forms of “non-personal information/data” which may be gathered/stored by us. The same has been discussed in detail in Paragraph 5 of this Privacy Policy.
TLC as a matter of policy never seeks, collects, processes or retains any of the Special Categories of Personal Data as mentioned in the EU General Data Protection Regulation, which are data/information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
TLC also as a matter of policy never seeks, collects, processes or retains any of the sensitive personal data or information as defined under the applicable Indian Laws. Sensitive personal data or information of a person under Indian Information Technology law means such personal information which consists of information relating to;— (i) password; (ii) financial information such as bank account or credit card or debit card or other payment instrument details ; (iii) physical, physiological and mental health condition; (iv) sexual orientation; (v) medical records and history; (vi) biometric information; (vii) any detail relating to the above clauses as provided to body corporate for providing service; and (viii) any of the information received under above clauses by body corporate for processing, stored or processed under lawful contract or otherwise: provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of these rules.
For the purpose of clarification, credit or debit card data or any financial information received by us to enable a transaction, example purchase of a membership program or to guarantee a reservation is used only for that transaction and is never stored by us. Further, if an activation code for a membership program is sent by us and converted into a changed password by the member, then that will be stored with us for the purpose of facilitating the access of the membership to that member. Activation codes and passwords are encrypted and collection of credit / debit card data follow PCI DSS certification.
TLC collects Personal Data in a variety of ways:
TLC collects your data, including Personal Data, to fulfill its obligations to its clients, customers and partners. TLC uses the Personal Data collected to acquire new customers and/or members and personalize and customize their loyalty membership programs and other user experiences and for enhancing the overall customer experience through life cycle management. The contact details are primarily used for passing on all kinds of information related to the User account or the membership account and it includes notifications, benefits, new offers, discounts, special packages and deals, renewals, post renewal offers, lapsed membership communication etc. that you are eligible to. We may contact you for administrative purposes, such as confirming a transaction you may have made, informing you of your account status, informing you of important product/service-related changes, or inviting you to reconsider your privacy preferences. We further use the Personal Data of a User and their family members (wherever applicable) to offer special services on their birthday, anniversary, etc. We further use the information provided by the Users pertaining to preferences/likings and interests to tailor-make and customize our offerings accordingly. Depending on the User’s request, the Personal Data collected will be processed by TLC in accordance with the following purposes:
We keep your Personal Data until the fulfillment of the purpose for which it was collected subject to any mandatory retention requirements under applicable laws. This means that we will keep your information for as long as you continue to be a User of our Services or our platforms or a member with any of our programs for fulfillment of the legal and contractual obligations entered into by you.
In case you cease to be a member or a User, we will retain your details for a further period of 36 months post expiration of the membership or your last transaction with us or deletion of your User account. This information would also help us communicate to you any new benefits, coupons, discounts, etc. that you may receive upon renewal of a hotel membership or renewal of your User account with us as well as allow you to easily rejoin when you wish to, within that period. Please note that you can always choose to opt-out from receiving such communications and also raise a request for removal of your information/data post expiry of your membership or deletion of your account by a click-through on each email you receive from us.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, disclose it to unrelated third parties or there is a change in our policies, we will notify you and we will explain the legal basis which allows us to do so.
This non-personal data can help us, for example, in controlling access to certain content on our site and in alerting users to new site content and services. This information is shared externally only:
We may provide links to third-party websites which are not controlled or operated by us. Please be aware that we do not control and are not responsible for the information collection practices of such third-party websites that may differ from those of our Websites and Apps. We are not responsible for and have no control over the practices and content of such websites accessed using the links contained in our Online Services /Tech Platforms. We encourage you to review and understand the privacy policies of these other websites before accessing and providing any information to them.
Further, any information you choose to directly share with a hotel, hotel company, restaurant partner and/or similar businesses or their respective employees or affiliates (for instance when you make a reservation and pay at the restaurant or avail certain services at a hotel) may be used by the hotel/restaurant for their own purposes. We do not control the privacy practices or policies of our partners and clients.
You have a right to access, rectify, restrict, suppress, update, and/or erase any or all of the Personal Data you submit to us by contacting us at privacyofficer@tlcgroup.com. If you would like to receive an electronic copy of your Personal Data for purposes of reviewing or transmitting it to another company (to the extent this right to data portability is provided to you by law) you can contact us at privacyofficer@tlcgroup.com. Individuals are informed, in writing, of the reason a request for access or correction of their Personal Data was denied, the source of TLC’s legal right to deny such access, and the individual’s right, if any, to challenge such denial. You can unsubscribe from receiving our emails by a click through on each email. You may also unsubscribe from mailing lists or any registrations on the Websites and Apps. To do so, please follow the instructions on the page of the email.
However, we may disclose your information, including Personal Data, if we believe it is necessary to protect the property and/or rights of TLC, you, or a third party, to protect the safety of the public or any person, in the event of a legal dispute, or to prevent or stop an activity we believe may pose a risk of being illegal, unethical or in violation of the terms of service. In case of such an event, the right to have the Personal Data rectified or erased may also stand suspended. However, you would still be able to view your Personal Data.
TLC has implemented generally accepted standards of technology and operational security to protect Personal Data from loss, misuse, alteration, or destruction. Only authorized TLC personnel have access to the Personal Data, and these employees are required to treat this information as confidential. TLC also has an ISO:27701 and ISO: 27001 certification in relation to data security and governance.
We maintain appropriate physical, technological, and organizational safeguards to protect your Personal Data against loss, misuse, unauthorized access or disclosure, alteration and destruction. Only authorized personnel of TLC have access to member/User accounts and details. Although we use reasonable measures to protect your Personal Data, it is important that you understand that no website or database is completely secure or "hacker proof". If you believe the security of your account has been breached, please contact us immediately at contactus@tlcgroup.com and privacyofficer@tlcgroup.com. Complaints and other disputes are escalated until they are resolved and a resolution is communicated to the individual in writing within a reasonable frame of time.
Our security procedures mean that we may occasionally request proof of identity before we disclose your Personal Data to you.
Personal Data collected may be transferred, from time to time, to TLC® offices or personnel or to third parties located throughout the world, and the Websites may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. TLC may store your Personal Data on the servers of Amazon Web services located in the USA, Salesforce located in India and Adobe Experience Cloud in Singapore. TLC has no control over, and is not responsible for, the performance, operation and security of such third party servers.
Cross border transfers are necessitated for providing seamless services to members/Users. For example, a member may travel outside the country of his ordinary residence and would want to avail benefits of our services abroad. To facilitate this, cross border transfer of information becomes necessary.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.
By using our Websites/Apps or by providing consent to us, you agree to the transfer of your Personal Data to countries outside of your country of residence for the purposes specified in this Privacy Policy. We ensure, by means such as contracts and personal data transfer agreements that your Personal Data is protected at all times in accordance with applicable privacy laws, regulations or binding codes.
The Personal Data that TLC collects may be disclosed to:
If you have any questions about the Policy or our privacy practices, please write to us at privacyofficer@tlcgroup.com.
If you choose not to receive any promotional communications from us or from our partners/clients, we will not send you promotional messages and will not share your Personal Data with our partners/clients or other companies for marketing or advertising purposes.
In order to discontinue receiving promotional communications from us, please write to us at privacyofficer@tlcgroup.com.
Any customer details collected on our Websites, Tech Platforms, Apps, through Social Media Pages, Digital Campaigns, emails, landing pages and other offline mediums, will allow TLC associates to, among others, call, SMS (regular and transaction related), Email, chat, send push notifications and WhatsApp the Users who have filled in their information. By dropping in details, the User explicitly allows and gives consent to TLC® and group companies to call him / her and such commercial & promotional communication would not be considered in violation of Do Not Call registration under TRAI’s Telecom Consumer Protection Regulations for such commercial & promotional communications.
If you have any questions or concerns, please contact our Grievance Redressal Officer Mr. Aditya Singh at grievanceredressal@tlcgroup.com.
The User:
UPDATES
The “Last Updated” legend at the bottom of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Online Services. Your use of the Services following these changes will constitute your consent and acceptance of the the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at contactus@tlcgroup.com.
Last updated: 18th August 2023
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