Updated December 27, 2019
TPG Rewards, Inc. is committed to maintaining your confidence and
trust as it relates to the privacy of your information. Please read below and
learn how we collect, protect, share and use your information during your
participation in any of our promotions and when you visit our technology
platforms, including, without limitation, our websites, interactive features,
applications, social network pages, and mobile application (“Platforms” or “promotions”).
GUIDE TO CONTENTS
- INFORMATION COLLECTED ON OUR PLATFORMS.
- HOW WE
USE THE INFORMATION WE COLLECT.
- SHARING OF INFORMATION.
WE RECEIVE FROM THIRD PARTIES.
PRIVACY RIGHTS, CHOICE AND ACCESS.
TARGETING; HOW TO OPT-OUT.
- CALIFORNIA PRIVACY RIGHTS.
OF YOUR INFORMATION.
TO PROCESSING AND TRANSFER OF INFORMATION.
- CONTACT US.
COLLECTED ON OUR PLATFORMS.
Information You Provide To Us
We may collect Personal Information
(information that can be used to identify you as an individual) such as your
name, email, telephone number, home address, demographic information (such as zip
code, age), or payment information (such as account or credit card number). The
types of Personal Information we collect may vary depending on your use of the
features of the Platforms. In many cases we need this information to provide the personalized or enhanced service that you are
interested in. You never have to answer our questions regarding your Personal
Information, and you can decline this exchange of information on any site on
the Internet - not just ours - at any time.
Information Collected Automatically
Information. Whenever you participate in one of our programs or visit or
interact with the Platforms, we, as well as any third-party advertisers and/or
service providers, may use a variety of technologies that automatically or
passively collect information about how the programs or Platforms are accessed
and used (“Usage Information”). Usage Information may include browser type,
device type, operating system, application version, the page served, the time,
the preceding page views, and your use of features or applications on the
Platforms, interaction with friends and group activities, information derived
from receipts, purchasing trends and online and offline activities and
interests. This information helps us keep our programs and Platforms fresh and
interesting to our visitors and allows us to tailor content to a visitor’s
interests. We may also anonymize or group this information into aggregate
visitor data in order to describe the use of the Platforms or promotions to our
existing or potential business partners, sponsors or other third parties.
Identifier. We automatically collect your IP address or other unique
identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet
or other device) you use to access the promotions or Platforms. A Device
Identifier is a number that is assigned to your Device when you access a
website or its servers, and our computers identify your Device by its Device
Identifier. We may use a Device Identifier to, among other things, administer
the Platforms, help diagnose problems with our servers, analyze trends, track
users’ web page movements, help identify you and your promotion entry, and
gather broad demographic information for aggregate use.
Pixel Tags. The technologies used in our promotions and on the Platforms to
collect Usage Information, including Device Identifiers, include but are not
limited to: cookies (data files placed on a Device when it is used to visit the
Platforms), mobile analytics software and pixel tags (transparent graphic
image, sometimes called a web beacon or tracking beacon, placed on a web page
or in an email, which indicates that a page or email has been viewed). Cookies
may also be used to associate you with social networking sites like Facebook,
Instagram, Twitter and YouTube and, if you so choose, enable interaction
between your activities on the Platforms and your activities on such social
networking sites we, or our vendors, may place cookies or similar files on your
Device for security purposes, to facilitate site navigation and to personalize
your experience while visiting our Platforms (such as allowing us to select
which ads or offers are most likely to appeal to you, based on your interests,
preferences, location, or demographic information). A pixel tag may tell your
browser to get content from another server.
To learn how you may be able to reduce the number of cookies you
receive from us, or delete cookies that have already been installed in your
browser’s cookie folder, please refer to your browser’s help menu or other
instructions related to your browser. If you do disable or opt-out of receiving
cookies, please be aware that some features and services on our Platforms may
not work properly because we may not be able to recognize and associate you
with your TPG Rewards account(s). In addition, the offers we provide when you
visit us may not be as relevant to you or tailored to your interests.
HOW WE USE
THE INFORMATION WE COLLECT.
We use the information we collect about and from you for a variety of
business purposes such as to respond to your questions and requests; provide
you with access to certain areas and features of the Platforms or programs and
your interaction with other users; verify your identity; communicate with you
about your account and activities on the Platforms and, in our discretion,
changes to any TPG Rewards policy; tailor content, advertisements, and offers
we or our business partners may serve you; improve the Platforms; comply with
license obligations; and for purposes disclosed at the time you provide your
Personal Information or otherwise with your consent. We may also collect your
location-based information for the purpose of providing you with certain services.
Legal Bases for
Processing (for EEA Users)
If you are an individual in the European Economic Area
(EEA), we collect and process your Personal Information only where we have
legal bases for doing so under applicable EU laws. The legal bases depends on the promotions you enter, how they operate, and
how you use them. This means we collect and use your Personal Information only
We need it to operate the promotion, provide customer
support and personalized features, help prevent fraud, and to protect the
safety and security of our platforms and promotion services;
It satisfies a legitimate interest (which is not overridden
by your data protection interests), such as for our internal development of
improved services, to market and promote the promotions, and to protect our
legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your Personal Information to comply with
a legal obligation or where the processing is necessary to the establishment,
exercise or defense of legal claims.
If you consented to our use of your Personal Information
for a specific purpose, you have the right to change your mind at any time but
note that this will not affect processing that has already taken place.
Where TPG Rewards is
using your Personal Information because our client and/or TPG Rewards have a
legitimate interest to do so, you have the right to object to that use although
this may mean no longer participating in a promotion. If we are unable to
manage your participation in a promotion without the Personal Information you
provided (such as your registration information), you will no longer be able to
participate in the applicable promotion. To learn how to opt-out of allowing
use of your Personal Information, please refer to Sections 5 and 6.
Except as described in this Privacy
Notice, we will not provide any of your Personal Information to any third
parties without your consent. We may share non-Personal Information, such as
aggregate data, demographic information, and Usage Information with third
parties. We may also share your information as disclosed at the time you
provide your information, as set forth in this Privacy Notice and in the
Parties Providing Services On Our Behalf and
Affiliates. We create promotions with consumer product companies, or other
clients, who sponsor the offers that we provide to you. In order to carry out
your requests, to make various features, services and materials available to
you in our promotions, and to respond to your inquiries, we may share your
Personal Information and Usage Information with such consumer product companies
and also third parties that perform functions on our behalf (or on behalf of
our partners) such as service providers that host or operate our Platforms,
analyze data, process transactions and payments, or provide customer service;
advertisers; sponsors or other third parties that participate in or administer
our promotions, contests, sweepstakes, surveys or provide marketing or
promotional assistance and “powered by” partners or partners in co-branded
sites. Your Personal Information may also be used by us or shared with our
subsidiaries, affiliates, sponsors, partners, advertisers or other third
parties to provide you with product information and promotional and other
Agreement To Have Your Personal Information Shared. While on
our Platforms, you may have the opportunity to opt-in to receive information
and/or marketing offers from someone else, such as a client or to otherwise
consent to the sharing of your information with a third party, including social
networking sites such as Facebook, Instagram, Twitter or YouTube. If you agree
to have your Personal Information shared, your Personal Information will be
disclosed to the third party and the Personal Information you disclose will be
Transfers. We may share your Personal Information with other entities and
our affiliates primarily for business and operational purposes. In the event that TPG Rewards is involved in a bankruptcy,
merger, acquisition, reorganization or sale of assets, your information may be
sold or transferred as part of that transaction.
Disclosure. We may transfer and disclose your information to third parties
to comply with a legal obligation; when we believe in good faith that the law
or other applicable policies; to address fraud, security or technical issues;
to respond to an emergency; or otherwise to protect our rights or property or
security of third parties, visitors to our Platforms or the public.
WE RECEIVE FROM THIRD PARTIES.
We may receive information about you from clients, affiliated
companies, or other third parties, in accordance with their terms and policies.
For example, if you are on another website and you opt-in to receive
information from TPG Rewards, that website will submit to us your email address
and other information about you so that we may contact you as requested. You
may also choose to participate in a third party application or feature (such as
one of our Facebook or Twitter applications or a similar application or feature
on a third party website) through which you allow us to collect (or the third
party to share) information about you, including Usage Information and Personal
Information such as lists of your friends, “likes”, comments you have shared,
groups and location. Services like Facebook Connect may give you the option to
post information about your activities on our Platform to your profile page to
share with others within your network. In addition, we may receive information
about you if other users of a third party website give us access to their
profiles and you are one of their “connections” or information about you is
otherwise accessible through your “connections’” web page, profile page, or
similar page on a social networking or other third party website or interactive
service. We may supplement the information we collect about you through the
Platforms with such information from third parties in order to enhance our
ability to serve you, to tailor our content to you and/or to offer you
opportunities to purchase products or services that we believe may be of
interest to you.
PRIVACY RIGHTS, CHOICE AND ACCESS.
You may always direct us not to share your Personal Information
with third parties, not to use your Personal Information to provide you with
information or offers, or not to send you newsletters, emails or other
communications by: (i) modifying your registered user
information on the Platforms; (ii) contacting us by mail at TPG Rewards Inc, 29
Broadway, Ste 1400, New York, NY 10006; (iii) following the removal
instructions in the communication that you receive; or (iv) sending us an email
at firstname.lastname@example.org. Please
make sure to include the name of the promotion (if one exists) in the subject
line and in the body of the email from which you wish to opt-out. Failure to
provide this information may delay the processing of your request.
If you wish to modify, verify, correct, or delete any of your
Personal Information collected through the Platforms, you may edit your
registered user information or contact us at the above address or email. In
accordance with our routine record keeping, we may delete certain records that
contain Personal Information you have submitted through the Platforms. We are
under no obligation to store such Personal Information indefinitely and
disclaim any liability arising out of, or related to, the destruction of such
Personal Information. It may not always possible to completely remove or delete
all of your information from our databases without
some residual data because of backups and other reasons. We will retain your
information (including geo-location data) for as long as your account is active
or as needed to provide you services. If you wish to cancel your account or
request that we no longer use your information to provide you services, contact
us at the above address or email. We will retain and use your information as necessary to comply
with our legal obligations, resolve disputes, and enforce our agreements.
We do not control certain privacy
settings and preferences maintained by our clients, social media partners like
Facebook, Instagram, Twitter and YouTube, or other relevant third party. If you
wish to make changes to those settings and preferences, you may do so by
visiting the privacy or settings page of the appropriate
client, social media site, or other relevant third party.
6. ADVERTISING/BEHAVIORAL TARGETING; HOW TO
We may use third party ad network providers to help present ads on
the Platforms, as well as other service providers to evaluate and provide us
with information about the use of the Platforms and viewing of our content. We
do not share Personal Information with these providers (unless, of course, you
give us permission). Such providers may place and access cookies, pixel tags,
or similar technologies on your Device to serve you ads or other content
personalized to your interests which they infer from your browsing on the
Platforms and other sites you have visited. In doing so, the provider collects
or has access to non-Personal Information such as your Usage Information. The
subject to their own privacy policies, not ours.
If you do not want to receive the
benefits of targeted advertising, you may opt-out of some network advertising
programs that use your information by visiting the NAI Opt-Out Page at http://www.networkadvertising.org/managing/opt_out.asp. Please note that even if you choose to remove
your information (opt-out), you will still see advertisements while you’re
browsing online. However, the advertisements you see may be less relevant to
you and your interests. Additionally, many network advertising programs allow
you to view and manage the interest categories they have compiled from your
online browsing activities. These interest categories help determine the types
of targeted advertisements you may receive. The NAI Opt-Out Page provides a
tool that identifies its member companies that have cookies on your browser and
provides a mechanism to opt-out of receiving cookies from those companies.
We do not knowingly collect, use or disclose personally
identifiable information from anyone under 13 years of age. If we determine
upon collection that a user is under this age, we will not use or maintain
his/her Personal Information without the parent/guardian’s consent. If we
become aware that we have unknowingly collected personally identifiable
information from a child under the age of 13, we will make reasonable efforts
to delete such information from our records.
In some instances, however, TPG Rewards does operate promotions on
behalf of clients that will collect personal data from children under the age
of 13. In each such instance, TPG Rewards will fully comply with the Children's
Online Privacy Protection Act (“COPPA”) or other applicable law when operating
the promotion, in the collection of the Personal Information, and in
subsequently using and deleting the data collected. Personal Information will
not be collected from children under the age of 13 without parental consent in
compliance with the COPPA guidelines.
For more information about the Personal
Information we collect, purposes for the collection of the Personal Information
and third parties with whom we might share the personal information, please see
the disclosures in this Privacy Notice. As a California resident, you may have
the right to request to access the Personal Information we have collected about
you during the past 12 months. In addition, you have the right to request that
we delete certain Personal Information we maintain about you, subject to
certain exceptions. Finally, you also have the right to opt-out of the sale of
your Personal Information. To submit a request to access, to delete, or
opt-out, you may contact us by (i) mail at TPG Rewards
Inc, Attention: Privacy, 29 Broadway, Ste 1400, New York, NY 10006; or (ii)
send us an email at email@example.com. Please make sure to
include the name of the promotion (if one exists) and California Privacy in the
subject line and in the body of the letter.
To help protect your privacy and maintain
security, we take steps to verify your identity before granting you access to
your personal information or considering your deletion or other request. Upon
receipt of your request, we will send you a verification form. 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. Please understand that
we cannot delete personal information in those situations where our retention
is required for our own internal business purposes or otherwise permitted by
the CCPA (such as fraud prevention or legal compliance).
9. SECURITY OF YOUR
We take information security seriously and use certain reasonable
security measures to help protect your Personal Information. However, no
electronic data transmission or storage of information can be guaranteed to be 100% secure.
Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us
with your information at your own risk.
10. OTHER SITES.
Platforms may contain links to other sites that we do not own or operate. This
includes links from advertisers, sponsors and/or partners that may use our
logo(s) as part of a co-branding or co-marketing agreement. We do not control,
recommend or endorse and are not responsible for these sites or their content,
products, services or privacy policies or practices. These other sites may send
their own cookies to your Device, they may independently collect data or
solicit Personal Information and may or may not have their own published
privacy policies. You should also independently assess the authenticity of any
site which appears or claims that it is one of our Platforms (including those
linked to through an email or social networking page).
The Platforms may make available
chat rooms, forums, message boards, and news groups. Remember that any
information that you disclose in these areas becomes public information and is
not subject to the provisions of this Privacy Notice.
11. CONSENT TO PROCESSING AND TRANSFER OF
The U.S. Platforms are governed by and operated in, and in
accordance with the laws of, the United States. Regardless of where you use our
Platforms or otherwise provide Personal Information and non-personally
identifiable information, that information may be collected, processed,
maintained and transferred to servers located in the U.S. and/or other
jurisdictions in which our service providers and affiliates may be located.
By using the Platforms, or providing us with any information, you
(a) acknowledge that the Platforms are subject to the laws of the United
States, (b) consent to the collection, processing, maintenance and transfer of
such information in and to the United States and other applicable territories
in which the privacy laws may not be as comprehensive as or equivalent to those
in the country where you reside and/or are a citizen, and (c) waive any claims
that may arise under those laws.
We may update this Privacy Notice
to reflect changes to our privacy practices. Any changes we may make to our
Privacy Notice will be posted on this page and/or communicated to you in other
ways if required by law. These changes will take effect immediately upon
posting. For your convenience, the last revised date of the current Privacy
Notice will be posted at the top of this page. We encourage you to periodically
review this page for the latest information on our privacy
practices. By continuing to use the Platforms following such changes, you will
be deemed to have agreed to such changes. Where required to do so by law, we
may seek your prior consent to any material changes we make to this Privacy Notice.
13. CONTACT US.
If you have any questions or
concerns about this Privacy Notice, the practices of the Platforms, or your
experiences with the Platforms, please contact us at:
TPG Rewards Inc., 29 Broadway, Ste 1400, New York, NY 10006
Telephone: (800) 838-4550