Privacy Notice
Updated July 28, 2020
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”).
QUICK GUIDE TO CONTENTS
1. INFORMATION 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
Usage 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.
Device 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.
Cookies; 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.
2. 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
where:
● 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 following circumstances:
Third 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 offers.
Your 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 subject to
the privacy policy and business practices of that third party, not ours.
Business 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.
Legal 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 a governmental authority requires it; to verify or
enforce our Terms of Use 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.
4. INFORMATION 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.
5. YOUR 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., 19790 West Dixie Highway, # 808, Aventura, FL 33180 ; (iii) following the removal instructions in
the communication that you receive; or (iv) sending us an email at customerservice@tpgny.com. 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 be 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 OPT-OUT.
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 use of cookies, pixel tags, or similar technologies by
these providers is 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, 19790 West Dixie Highway , # 808, Aventura, FL 33180; or
(ii) send us an email at customerservice@tpgny.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 INFORMATION.
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.
The 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 INFORMATION.
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.
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., 19790 West Dixie Highway, #
808, Aventura, FL 33180
Telephone: (800) 838-4550
Email: Customerservice@tpgny.com