NOTE: Your wireless operator, mobile operating system provider and/or third-party applications, toolbars, services, “plug-ins”, social media platforms and websites may also collect, use and share information about you and your device and your usage. TFW’s privacy policies do not cover any third parties, their products, actions or their services. TFW does not control how third parties collect, use or secure your data. For information about third-party privacy practices, please consult their privacy policies. We would like to inform you regarding the storage of information on the basis of the following relevant points:
1. INFORMATION YOU GIVE US
2. INFORMATION WE AUTOMATICALLY COLLECT
3. USE OF YOUR PERSONAL INFORMATION
4. MORE ABOUT LOCATION DATA
5. SHARING OF PERSONAL INFORMATION
6. WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION
8. YOUR RIGHTS
9. INFORMATION CHOICES AND CHANGES
10. SECURITY OF YOUR PERSONAL INFORMATION
11. CONTACT INFORMATION
INFORMATION YOU GIVE US
When you use our Services, you may provide information to us, both online and offline, including, for example: your name, email address, street address, mobile numbers, date of birth, location data, your provider information, photos, videos and demographics (gender, company or organisation name, occupation, language preference, city, country, postcode, area code, time zone, etc.). If you purchase Services from us, we may also store your credit card numbers or other payment information, as required. We may hold and associate any information you provide us with together with information gathered from other sources, including the social accounts that you choose to associate with your use of the Services, or with information we receive from other companies.
INFORMATION WE AUTOMATICALLY COLLECT
INFORMATION COLLECTED THROUGH THIRD PARTY
USE OF YOUR PERSONAL INFORMATION
TFW may use your information, including personal information, as follows:
1. To provide requested services or perform a contract with you;
2. To provide and deliver products and Services that you request;
3. To process the post transaction requested by you, such as refund;
4. To send you information related to your requests, queries and purchases, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
Where we have your consent
To send you marketing communications including about contests, promotions, rewards, upcoming events and news about products and services offered by TFW and our selected partners (we do this as per your choices) and to process and deliver contest entries and rewards. Where we have a legitimate interest in improving your customer experience and the quality of the Services provided to you:
1. To operate and improve our websites, products, Services and marketing;
2. To respond to your comments and questions and provide customer service;
3. To compile information to be able to provide you with a personalized and customized experience, content, marketing and recommendations across all our Services (in line with your choices as relates to receiving any direct marketing communications);
4. To link or combine
5. your personal information with other information we get about your use of other TFW Services and from third parties for the purposes that we disclose in this policy, including to help understand you and your needs, and provide you with recommendations, better service and customised marketing;
6. To filter the content to be displayed as part of the Services;
7. To compile usage and other statistics and insights relating to the Services;
8. To prevent, investigate and deter against fraudulent, unauthorised or illegal activity, and ensure network and information security; and
9. To facilitate sharing of information and content that you choose to upload via social media (for example if you choose to upload content on the TFW forum or other applications, this may be made available for others to see through such forum).
10. Where we have a legal obligation
11. To protect, investigate and deter against fraudulent, unauthorised or illegal activity.
Where your personal information is necessary for us to be able to provide you with requested services we make this clear on collection. If you decline to provide us with this information or object to continued processing of this information we will be unable to provide such requested services to you. If you object to the processing of your personal data for marketing communication or if you withdraw your consent, we are obliged, according to data protection law, to enter the required data (name, e-mail address) into our internal emailing system in order to ensure the ongoing observance of your objection or of your withdrawal of consent. We will use your blocked data exclusively for this purpose.
MORE ABOUT LOCATION DATA
When you use certain Services, we may collect, process, store and share your precise location data. This location information may include real-time geographic location of your device. It may also include the names of places that you have been, where you choose to “check-in”, to determine, log or share your location, places that you mark on a map, the geographic location, dates and other metadata of photos that you’ve taken, routes that you have travelled, how close you are to other devices, such as Bluetooth-enabled devices, Wi-Fi routers and services that use those devices (such as a store’s tracking of your movement for data collection and marketing purposes) and the dates and times that you were at certain locations. TFW may share your location data with application providers who show that they have the right permissions. TFW may associate location data with personally identifiable or identifying information, such as your device ID and your account information. Our Services may also collect precise location data in a de-identified form, and we may share this data with partners and carriers to improve features and services.
SHARING OF PERSONAL INFORMATION, INFORMATION YOU SHARE
The Services may allow you to connect and share your actions, comments, content and information publicly or with people you specify. You may also connect to, and share your information on, third-party social media platforms, websites, applications and services (“Third Party Sharing Services”) through “plug-ins,” widgets, buttons, and other third party features made available on and connected with our Services. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information that you choose to make public or share with others. We also cannot control and are not responsible for any Third-Party Sharing Services or their actions, including the data that these Third-Party Sharing Services collect from you and your device, or how they use such data. Please review the privacy policies of all Third-Party Sharing Services to understand their privacy practices.
INFORMATION WE SHARE
We may share your personal information as follows where it is lawful to do so.
We share your personal information with ad network providers where you have given your consent. We also share your personal information with co-branded partners where you have consented to this. Our partners’ use of your personal information will be subject to their privacy policies.
For the purposes of a business deal (or negotiation of a business deal) involving a sale or transfer of all or a part of our business or assets. Business deals may include any merger, financing, acquisition or bankruptcy transaction or proceeding.
For legal, protection, security and safety purposes
1. to comply with laws or regulatory requirements and to respond to lawful requests and legal processes;
3. In an emergency, including protecting the safety of our employees and agents, our customers or any other person.
With service providers who process personal information as part of services to us and who are subject to appropriate contractual obligations.
We may share aggregated and de-identified data with others for any purpose.
WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION
Information that we collect may be stored on your phone or stored on our servers and transferred to, stored and processed in any geolocation where TFW or its service providers maintain facilities, depending on where you use our product and services. Security measures and appropriate safeguards are put in place to protect your information and we ensure that all transfers of your information comply with applicable data protection law, and are carried out in accordance with our instructions.
Information that we collect may be retained for as long as needed to fulfil the purposes outlined in the “use of your personal information” section above, or for a period of time specifically required by applicable regulations or laws such as retaining the information for tax and accounting purposes. When determining the relevant retention periods, we will take into account factors including:
1. our contractual obligations and rights in relation to the information involved;
2. legal obligation(s) under applicable law to retain data for a certain period of time;
3. statute of limitations under applicable law(s);
4. (potential) disputes; and
5. Guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed. Contact us if you would like more information on how long we retain your information.
YOUR RIGHTS By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our contact information below.
1. The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services which we think will be of interest to you or being contacted with varying potential opportunities).
2. The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
4. The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold.
5. The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
6. The right to restrict processing. You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.
7. The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator.
8. The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your information at any time.
INFORMATION CHOICES AND CHANGES
While we and others give you certain choices, as further outlined in this Policy, there are many ways in which Web browser signals and similar mechanisms can indicate your choice to disable tracking, and we may not be aware of nor honor every such mechanism.
PROTECTION OF YOUR PERSONAL INFORMATION
We strive to protect personal information by taking appropriate physical, technical and organisational measures to help guard against unauthorised or unlawful access, use, processing or alteration of the personal information that we obtain from you through our Services and against any breaches or loss of such personal information, such as anonymization, pseudonymization, encryption (such as encrypted by Transport Layer Security (HTTPS) during transmission), restricted access, etc. Although we take steps to use and improve various safeguards, no system or technology is completely secure.