Privacy Policy

PREAMBLE

TLC Relationship Management Private Ltd. 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 to understand and exercise choices available to you in this regard.

This Privacy Statement describes the privacy practices of the TLC for the data that we collect

Collectively, we refer to the Websites, the Apps, Digital Campaigns 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 those of third parties, to TLC, its group companies and their affiliates.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as providing a membership benefit), 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 Relationship Management Pvt. Ltd.

REGISTERED OFFICE: 501, Salcon Aurum, Jasola District Centre, New Delhi-110 025, India

EMAIL: contactus@tlcgroup.com

DATA PRIVACY OFFICER (DPO) MAIL: privacyofficer@tlcgroup.com

TLC is primarily in the business of marketing and managing loyalty memberships for its clients. Details of its various services and clients is available on www.tlcgroup.com. TLC uses sources of information as above to enroll new members to its loyalty programs and then service those memberships using the information provided by such Members. It has its own proprietary software and mobile app to manage these memberships. The information provided to TLC by its Members is shared with the hotels and hotel companies whose membership programs TLC manages and Program Partners, if any, in conformity with the respective privacy policy of TLC and such hotels and Program Partners.

1. INFORMATION AND CONSENT: SCOPE OF THIS PRIVACY POLICY

This Privacy Policy (‘Policy’) describes how TLC protects your privacy when we receive your information from the various channels as mentioned above. This Policy may be supplemented or amended from time to time.

This Policy is part of the terms and conditions of the membership program you enroll for (as detailed in the program brochure) or any marketing and sales promotion to acquire new members run by TLC or its group companies.

By providing us with your information as described above, you are expressly agreeing to our terms and conditions, including the terms of this Policy. If you do not consent to the collection, use, disclosure and transfer of your personal information as described in this Policy, you may choose not to provide us the information as described above.

2. NATURE OF DATA: PERSONAL INFORMATION/DATA

As used in this Policy, the term “personal information/data” means 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 manage your membership effectively. We use your personal information to administer the Program, respond to your queries and communicate with you about Program related offers, transactions and ancillary services. The personal information/data you provide directly to us generally includes 

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 6 of this Privacy Policy.

SENSITIVE PERSONAL DATA THAT WE DO NOT COLLECT

TLC as a matter of policy never seeks, collects, processes or retains any of the Special Categories of Personal Data as mentioned in the GDPR, 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 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 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 credit / debit card data follow PCI DSS certification.

3. HOW WE COLLECT PERSONAL DATA

TLC collects Personal Data in a variety of ways

4. WHAT WE DO WITH THE DATA WE COLLECT AND FOR HOW LONG WE KEEP IT

TLC uses the personal data collected to acquire new Members and personalize and customize their loyalty membership programs for enhancing the overall experience of the existing members. The contact details are primarily used for passing on all kinds of information related to their membership account and it includes notifications, benefits, new offers, discounts, special packages and deals, renewals, post renewal offers, lapsed membership communication etc. that a member is 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 Program changes, or inviting you to reconsider your privacy preferences. We further use the personal information of the member and their family members (wherever applicable) to offer special services on their birthday, anniversary, etc. We further use the information provided by the members pertaining to preferences/likings and interests to tailor-make and customize our offerings accordingly. Depending on the member’s request, the personal data collected will be processed by TLC in accordance with the following purposes

We keep your personal information till the fulfilment of the purpose for which it was collected. This means that we will keep your information for as long as you continue to be a member with any of our programs for fulfillment of the legal and contractual obligations entered into by the members by accepting the loyalty membership.

In case you cease to be a member, we will retain your details for a further minimum period of 24 months post expiration of the membership so that you may easily rejoin when you wish to within that period. This information would also help us communicate to you any new benefits that you may receive with a renewal of membership. 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 by a click-through on each e-mail you receive from us.

We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. COLLECTION OF OTHER DATA

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

(i) in anonymous, aggregated form for generalized user analysis, or

(ii) to review whether users qualify for additional benefits, or

(iii) to enable us to send e-mails to you on our behalf.

6. LINKS TO THIRD-PARTY SITES

We may provide links to third-party websites. Please be aware that we do not control and are not responsible for the information collection practices of such third-party websites’ policy that may differ from those of this Site. We encourage you to review and understand the privacy policies of these other Web sites before accessing and providing any information to them.

7. RIGHTS OF DATA SUBJECTS: INFORMATION ACCESS, CHANGE, AND/OR DELETION

You have a right to access, rectify, restrict, suppress, update, and/or erase any or all of the personal information that 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 your purposes of review 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. You can unsubscribe from receiving our e-mails by a click through on each e-mail. You may also unsubscribe from mailing lists or any registrations on the Site. To do so, please follow the instructions on the page of the e-mail.

However, we may disclose your information, including personal information, 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 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 information rectified or erased may also stand suspended. However, you would still be able to view your personal information.

8. SECURITY MEASURES

TLC has implemented generally accepted standards of technology and operational security to protect personally identifiable information from loss, misuse, alteration, or destruction. Only authorized TLC personnel have access to personally identifiable information, and these employees are required to treat this information as confidential.

We maintain appropriate physical, technological, and organizational safeguards to protect your personal information against loss, misuse, unauthorized access or disclosure, alteration and destruction. Only authorized personnel of TLC have access to member accounts and details. Although we use reasonable measures to help protect your personal information, 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.

Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

9. CROSS BORDER TRANSFER AND SHARING OF INFORMATION

Personally identifiable information collected may be transferred, from time to time, to TLC® offices or personnel or to third parties located throughout the world, and the website 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 USA, Net4India located in India and GoDaddy in Singapore.

Cross border transfers are necessitated for providing seamless services to members. For example, a member may travel outside the country of his ordinary residence and would want to avail benefits of the membership 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 website or by providing consent to us, you agree to the transfer of your personal information 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

10. CONTACT US

If you have any questions about this Policy or our privacy practices, you may contact us at answers@tlcgroup.com or write to us at TLC Relationship Management Pvt. Ltd. PO Box 3640, New Delhi - 110 024, India.

11. COMMERCIAL & PROMOTIONAL COMMUNICATIONS: DO NOT CALL
12. USER’S RESPONSIBILITY/ DECLARATIONS

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 means that you accept 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: 24th May 2018