This policy describes the information we process to support The Privilege Card, henceforth known as TPC, and other products and features offered by TPC.
To provide TPC Products, we must process information about you. The types of information we collect depend on how you use our Products.
Things you and others do and provide.
As described below, we collect information from and about the computers, phones, connected TVs and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalize the content (including ads) or features you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device.
Information we obtain from these devices includes:
Information from partners.
Advertisers, app developers, and publishers can send us information through TPC Business Tools they use, including our social plug-ins, TPC Login, our APIs and SDKs, These partners provide information about your activities off TPC—including information about your device, websites you visit, purchases you make, the ads you see, and how you use their services—whether or not you have a TPC account or are logged into TPC. For example, a business could tell us about a purchase you made in its store. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information.
Partners receive your data when you visit or use their services or through third parties they work with.
We use the information we have (subject to choices you make) as described below and to provide and support the TPC Products.
Provide, personalize and improve our Products.
We use the information we have to deliver our Products, including to personalize features and content and make suggestions for you (such as groups or events you may be interested in or topics you may want to follow) on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others (including any data with special protections you choose to provide); how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products.
Information across TPC Products and devices: We connect information about your activities on different TPC Products and devices to provide a more tailored and consistent experience on all TPC Products you use, wherever you use them. For example, we can suggest that you join a group on TPC that includes people you follow on Instagram or communicate with using Messenger. We can also make your experience more seamless, for example, by automatically filling in your registration information (such as your phone number) from one TPC Product when you sign up for an account on a different Product.
We use the information we have (including your activity off our Products, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.
Promote safety, integrity and security.
We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of TPC Products. For example, we use data we have to investigate suspicious activity or violations of our terms or policies.
Communicate with you.
We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
Research and innovate for social good.
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.
Your information is shared with others in the following ways:
Sharing on TPC Products
Apps, websites, and third-party integrations on or using our Products.
When you choose to use third-party apps, websites, or other services that use, or are integrated with, our Products, they can receive information about what you post or share. For example, when you play a game with your TPC friends or use a TPC Comment or Share button on a website, the game developer or website can receive information about your activities in the game or receive a comment or link that you share from the website on TPC. Also, when you download or use such third-party services, they can access your public profile on TPC, and any information that you share with them. Apps and websites you use may receive your list of TPC friends if you choose to share it with them. But apps and websites you use will not be able to receive any other information about your TPC friends from you. Information collected by these third-party services is subject to their own terms and policies, not this one.
Devices and operating systems providing native versions of TPC (i.e. where we have not developed our own first-party apps) will have access to all information you choose to share with them, including information your friends share with you, so they can provide our core functionality to you.
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
Sharing with Third-Party Partners
We work with third-party partners who help us provide and improve our Products or who use TPC Business Tools to grow their businesses, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:
Partners who use our analytics services.
We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, Pages, videos and other content on and off the TPC Products.
We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes software engineering) to help them better understand their audience. We also confirm which TPC ads led you to make a purchase or take an action with an advertiser.
We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.
Partners offering goods and services in our Products.
When you subscribe to receive premium content, or buy something from a seller in our Products, the content creator or seller can receive your public information and other information you share with them, as well as the information needed to complete the transaction, including shipping and contact details.
Vendors and service providers.
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.
Law enforcement or legal requests.
We share information with law enforcement or in response to legal requests.
TPC may share infrastructure, systems and technology with other TPC Companies (which include SmartCardz LLP) to provide an innovative, relevant, consistent and safe experience across all TPC Company Products you use. We also process information about you across the TPC Companies for these purposes, as permitted by applicable law and in accordance with their terms and policies.
We provide you with the ability to access, rectify, port and erase your data.
We store data until it is no longer necessary to provide our services and TPC Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, when you search for something on TPC, you can access and delete that query from within your search history at any time, but the log of that search is deleted after 6 months. If you submit a copy of your government-issued ID for account verification purposes, we delete that copy 30 days after submission.
When you delete your account, we delete things you have posted, such as your photos and status updates, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead.
We access, preserve and share your information with regulators, law enforcement or others:
Information we receive about you (including financial transaction data related to purchases made with TPC) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.
We share information globally, both internally within the TPC Companies, and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy.
We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.
You can learn more about how privacy works on TPC. If you have questions about this policy, you can contact us as described below.
You can contact us online or by mail at:
2 Sim Close #03-10
Gemini @ SIms
Date of Last Revision: 27 March, 2019