This policy is for people whose personal information we use as part of TLC’s business.
Whenever we collect personal information, we will be up front about this and will explain what we intend to do with it. We will also give you clear options regarding the ways in which your personal information is used.
Below we explain how TLC uses (and protects) personal information – including information from the use of our website and participating in promotions organised by TLC and our partners. Consequently, please read the following carefully to understand how we use your personal information and, importantly, your rights.
TLC Marketing UK Limited’s ICO registration number is Z2323468 and our entry on the register can be viewed here. However, in this policy, ‘we’, ‘our’ and ‘TLC’ each mean all the companies that make up the TLC Group.
We collect and use the following types of personal information:
· Contact information (for example, your name, username, address, email address and phone numbers).
· Basic information about you (for example, age, your date of birth).
· Details of any contact or correspondence we have had with you.
· Financial details (for example, details about any payments you have made to us and where necessary your bank details).
· Information about how you use our services and promotions.
· Information about your consumer preferences.
· Information about how you use our website (for example, traffic data, location data, weblogs and other communication data.
· Information about your computer, including where available your IP address, operating system and browser type.
· Register or fill in forms on our site (www.tlcmarketing.com).
· Subscribe to our mailing lists.
· Participate in any promotions or competitions sponsored, promoted or offered by us or one of our partners.
· Give us feedback, correspond with us or report a problem with our site.
· Take part in consumer research.
· Use our site.
· Products or services you have requested either from us or our partners.
· A personalised experience and understand your needs better.
· Relevant marketing communications and adverts.
· Updates from us or our partners which you have asked for.
· Important information relating to products, services or promotions (for example, confirming your order, reminding you of an upcoming event or letting you know about changes that may affect you).
· Emails about specific topics, news and updates you have requested to hear about.
· Opportunities to take part in consumer research.
We also use your information to:
· Measure and understand how people respond to a variety of marketing activity so that we can ensure our work is well-targeted, relevant and effective.
· Analyse and continually improve the services we offer, our website and our other products.
· Keep our accounts, records and databases accurate and relevant.
· Support and manage out staff.
· Fulfil our legal obligations to regulators and official authorities.
· Exercise our legal rights (including in relation to legal proceedings).
In addition, we sometimes have to use personal information to detect and reduce fraud and we use CCTV recording equipment around our premises for security purposes.
If you are an individual consumer, we will seek your consent for direct marketing by either us or our partners. We will also seek your consent to use your personal information to undertake consumer research. We may also seek your consent for other specific products, services or promotions. We will let you know when we do.
Where we have a contract with you, we will also use your personal information where necessary for the purposes of the contract. Importantly, if you do not provide us with enough personal information, we may not be able to enter into or fulfil a contract with you.
In other situations, our ground for the use of your personal information is for the purposes of the legitimate interests of our business. We will always consider your rights and your privacy before using your personal information for the purposes of our business. Where your rights or privacy override our business interests, we will not use your personal information.
Separately from our business purposes, we will also use your personal information where we have a legal obligation to do so. For example, if a regulator or official authority asks us for your personal information.
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 where necessary or appropriate.
We do not use automated decision making on our website.
We share your personal information with the following organisations that handle or store information on our behalf –
· Dot Mailer
· Survey Monkey
In some cases we also share information with partner organisations which are involved in the products, services or promotions. For example –
· Brand partners
· Independent partners
· Digital Agencies
· Fulfilment houses
Some of our offices and the partners we work with are based outside of the European Economic Area (EEA). When we send your personal information outside of the EEA to a country not recognised as providing appropriate protections, we put in place appropriate contracts, group agreements or other safeguards to ensure your rights are protected.
To help TLC operate our service and meet our legal obligations we will store personal information for six years after the date of the product, service or promotion for which the information was used originally used. We will only hold information for a longer or shorter period where we are under a legal obligation to do so.
It is important that you are familiar with and easily able to exercise the following rights:
· The right to be informed personal information relating to you is being used or stored (which is what this privacy notice is for).
· The right to access personal information relating to you which we use or hold.
· The right to object to direct marketing.
· The right to object to the use of personal information relating to you carried out on the ground of legitimate interests.
· The right to withdraw consent to the use or storage of your personal information.
· The right to erasure of information relating to you that we use or hold (only in some circumstances).
· The right of data portability.
· The right to have personal information relating to you rectified if it is inaccurate.
· The right to have personal data relating to you restricted or blocked from being used or stored.
Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them or they are not relevant. To help you understand how they work, we have provided links to the Information Commissioner’s Office’s guidance on each of the rights.
London W1H 4HF
You can send your request to Privacy@tlcmarketing.com with these details.
1. First Name – 2. Middle Name – 3. Last Name – 4. Email ID – 5. Contact telephone or mobile number – 6. Resident Country – 7. Name of the campaign you were part of – 8. Name of the website where you submitted your details – 9. Proof of your identity, for example a utility bill – 10.Other details or documents that will help us find the data you are requesting (e.g. data you want to receive, or emails). Please be as specific as possible and provide a date range where applicable.
For documents, please scan and attach them to your reply. To make sure we receive everything, please make sure your email (and all the images in it) is less than 10mb in size.
If you have or have participated in multiple campaigns and you want data for more than one, please provide the above details for each of the campaign.
Once we have received the additional info we will get to work on your requests and get back to you within one month. You also have a right to make a complaint to your local privacy supervisory authority. Our main establishment is in the UK, where the local supervisory authority is the
Information Commissioner’s Office
United SK9 5AF
Phone: 0303 123 1113 or
01625 545 745
www.tlcmarketing.com is a site operated by TLC Marketing UK Ltd (we), a company incorporated and registered in England and Wales with company number 06821393 whose registered office is at 19 Harcourt Street, London,W1H 4HF . Our main trading address is 19 Harcourt Street, London, W1H 4HF. Our VAT number is 947 1358 04.
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.
You are responsible for making all arrangements necessary for you to have access to our site. 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.
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. Those works 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 Worldwide PTY Limited. Nothing contained on this site should be construed as granting, by implication, or otherwise, any licence 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 organisation to material posted on our site.
You are also advised that we will enforce our intellectual property rights to the fullest extent permitted by the law.
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.
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 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.
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, warranties and other terms which might otherwise be implied by statute, common law or the law of equity
Incompatibility of our site with any of your computer equipment, software or telecommunications links.
Unsuitability, unreliability or inaccuracy of 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). 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.
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.
Any material you upload to our site will be considered non-confidential and nonproprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. 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. 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.
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. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach 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.
You may not link to our home page 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 firstname.lastname@example.org.
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.
Information we may collect from you What information we collect depends upon the nature of our relationship with you and our relationship with your employer/company (if applicable). Importantly, in some circumstances if you do not provide the information that we request, you (and your employer/company, if applicable) may not be able to use or access the relevant service or the site or receive a stated benefit. We may collect and process the following information about you: • Information that you provide by registering or by filling in forms on any of our campaign websites (our site), including but not limited to your name, address, contact details, age and other information about you and/or your preferences/opinions about certain topics. This includes information provided at the time of subscribing to any services we offer, downloading information posted on our site, posting material or requesting further services. • We may also ask you for information in connection with or participation in any promotions, offers or competitions sponsored, promoted or offered by us and/or any third party (such as our clients), including but not limited to your name, address, contact details, age and other information about you and/or your preferences/opinions about certain topics. We may also receive your information from third parties (such as our clients) in some limited circumstances (for example in order to award you a prize). • Information you provide when giving us feedback or completing profile and/or survey forms (including but not limited to name, address, contact details, age and other information about you and/or your preferences/opinions about certain topics) and when you report a problem with our site or one of our promotions or competition. • Information we learn from your use of any of our services and/or your visits to our site and other information from your interaction with our site, services, content and advertising, including computer and connection information, statistics on page views, traffic to and from the site, ad data, IP address and standard web log information. • If you contact us (be it online, via phone, mail, in person or via any other method), we may keep a record of that correspondence. • Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
IP addresses and cookies We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us: • To estimate our audience size and usage pattern. • To store information about your preferences and so allow us to customise our site according to your individual interests. • To speed up your searches. • To recognise you when you return to our site.
Disclosure of your information Due to the international nature of our business, we may disclose your personal information to members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries in both Australia and overseas. We may also pass your personal information on to any successor or potential successor in title, to our suppliers, contractors and agents that process information on our behalf both in Australia and overseas. We may also disclose your personal information to our clients/partners, on whose behalf we conduct/facilitate an activity (e.g. a company whose promotion/offer you participate in). In addition, we may also disclose your personal information to selected other business partners so that they can contact you with information about products/services that may be of interest to you, where you have consented to this. Recipients located overseas that we may disclose your personal information to will be located in the United Kingdom, unless indicated otherwise. All overseas recipients of personal information as contemplated above are subject to a law or binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar or more stringent to the way in which the Australian privacy law protects the information. In addition, there are adequate means available in those jurisdictions for individuals to take action or enforce their rights in those jurisdictions under the laws/binding schemes mentioned above. In any event, we will use all practicable measures to ensure that any overseas recipient complies with Australian privacy law to the extent possible. Where required by law, we may also disclose your personal information to the appropriate regulatory authorities. We may also disclose (and use) information in aggregate (so that no individual person is identified) for marketing and strategic purposes.
We will use your personal information for the reasons we collected it and for other related purposes. For example, we may use information held about you in the following ways: • To ensure that content from our site is presented in the most effective manner for you and for your computer. • 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. • To carry out our obligations arising from any contracts entered into between you and us, including to award you a gift or a prize. • To allow you to participate in interactive features of our service, when you choose to do so. • To contact you for your views on our services and to notify you about changes or developments to our service.
Where you have consented to be contacted for such purposes, we may also use your personal information, or permit selected third parties to use your personal information, to provide you with information about goods and services which may be of interest to you, and we or they may contact you about these by email, post or telephone for an indefinite period unless otherwise advised.
If you are a new customer, and where we permit selected third parties to use your information, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your personal information in these ways, or to pass your details on to third parties for marketing purposes, please contact us directly by post at TLC Marketing Worldwide Asia Pacific Pty Ltd, Ground Floor, 320 Pitt Street, Sydney 2000, Australia or by email at email@example.com.
Your rights Marketing information and other websites You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by contacting us directly by post at TLC Marketing Worldwide Asia Pacific Pty Ltd, Ground Floor, 320 Pitt Street, Sydney 2000, Australia or by email at firstname.lastname@example.org. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or these websites. Please check these policies before you submit any personal information to these websites.
Access to and correction of information You have the right to access and correct personal information we hold about you. Your right of access and correction can be exercised by contacting us at TLC Marketing Worldwide Asia Pacific Pty Ltd, Ground Floor, 320 Pitt Street, Sydney 2000, Australia or by email at email@example.com. No fee will be charged for making the request, however, we may charge a fee for the provision of this information to cover administrative costs (and we will inform you of any such fee at the time the request is made). Please note that we may deny access/correction of personal information to you to the extent that: • providing access/correction would pose a serious threat to the life or health of any individual; • providing access/correction would have an unreasonable impact upon the privacy of other individuals; • your request for access/correction is frivolous or vexatious; or • it is otherwise appropriate for us to deny access/correction in accordance with the applicable privacy laws.
Complaints You should also contact us at TLC Marketing Worldwide Asia Pacific Pty Ltd, Ground Floor, 320 Pitt Street, Sydney 2000, Australia or by email at firstname.lastname@example.org if you are concerned that there may have been a breach of your rights or any rights under the Privacy Act 1988. We take such matters very seriously and, we shall respond to any such concerns to you directly in a prompt fashion.