The Reward Company, Inc. Privacy Policy

The Reward Company, Inc. d/b/a/ TLC Marketing Worldwide ("TLC") is committed to protecting your privacy. This Privacy Policy relates to TLC's use of any personal information which you provide to us via websites, phone, email and post for the purposes of your participation in the Olive Garden® "Fun Pass" Back to School Promotion (2015) ("Promotion"). All websites related to this Promotion which are controlled by TLC and where this privacy policy ("Policy") is posted or referenced (collectively, the "Sites") are covered by this Policy.

1 Information Collected -

Two types of information are collected from visitors to the Sites and participants in the Promotion:

  • Personally Identifiable Information necessary to fulfill the Promotion will be collected by TLC and used only for such specific purpose, after which it will be transferred to the Darden Corporation d/b/a Olive Garden ("Olive Garden")
  • Non-Personally Identifiable Information will be collected directly by Olive Garden and will also be subject to their privacy policy, which can be found at http://www.olivegarden.com/privacy-policy.

 

1.1 Personally Identifiable Information ("PII")


The term "Personally Identifiable Information" of "PII" is considered information that identifies you personally, such as your name, address, telephone number, email address, or company name. TLC may collect and store the Personally Identifiable Information that you have provided to us for as long as necessary for TLC to fulfil its obligations under the Promotion.

Here are some examples of manners in which TLC may collect a user's Personally Identifiable Information:

  • TLC may collect your name, email address, mailing address and additional information contained in an online form on the Sites to us if you participate in the Promotion.
  • TLC may collect your name, email address, mailing address and additional information contained in a printed form and mailed to TLC if you participate in the Promotion.
  • TLC may collect your name, email address, phone number and additional information if you contact TLC with a question related to our services or other promotional campaigns.
  • TLC may collect your date of birth if you participate in the Promotion and the Promotion has age restrictions on making a qualifying purchase or on the redemption of a reward.

The above list is not exhaustive but provides examples of the Personally Identifiable Information that may be collected by TLC pursuant to your participation in the Promotion. If you do not want TLC to collect your Personally Identifiable Information, please do not provide it to TLC and please suspend your participation in the Promotion. If you have already provided TLC with your personal data and decide that you would otherwise rather not participate in the Promotion, please contact us immediately via email on privacy@trcoworld.com and request a deletion of your record.

 

1.2 Non-Personally Identifiable Information


Generally speaking, the term "Non-Personally Identifiable Information" is normally considered either technical information or demographic information or both, such as your age, location, gender or interests, which cannot be used to identify you personally. Because the Non-Personally Identifiable Information will be collected by Olive Garden® the definition of such term will be subject to the Olive Garden® privacy policy (link found below). Non-Personally Identifiable Information does NOT identify you personally. Some examples of the Non-Personally Identifiable Information that may be collected via our Sites are:

  • Internet Protocol (IP) address. Your IP address is the address used to locate your computer on the Internet.
  • Internet Browser type (Google Chrome, Internet Explorer, Firefox, Safari, etc.).
  • Statistics on page views.
  • Pin code that provides access to participate in a promotional campaign, if any.
  • Cookies

TLC will not collect the above Non-Personally Identifiable Information from the visitors to the Promotion website. Rather, the Non-Personally Identifiable Information will be collected by Olive Garden® and subject to their privacy policy located at http://www.olivegarden.com/privacy-policy. If you do not want Olive Garden® to collect this data, please do not visit the Promotion website and remove all cookies from your preferred web browser. Further details on removing Cookies is available on and can be seen at www.aboutcookies.org.

2 Use of Information by TLC -

2.1 Personally Identifiable Information


We use your personally identifiable information that is collected primarily for the following:

  • To fulfill reward requests for the Promotion that you are participating in.
  • To provide you with information on products or services you have requested.
  • To ensure the Sites are relevant to your needs with respect to the Promotion.
  • To allow you access to limited-entry areas of the Sites with respect to the Promotion.
  • To contact you in response to sign up forms such as Contact Us or other inquiry
  • If you have opted in to receive notifications on future rewards or promotional campaigns from TLC.

Following TLC's use of your Personally Identifiable Information for the purpose of fulfilling TLC's obligations under the Promotion, the Personally Identifiable Information will be transferred to the Darden Corporation d/b/a Olive Garden®. Following such transfer, Darden Corporation d/b/a Olive Garden® will have access and control over your Personally Identifiable Information. Following the transfer of Personally Identifiable Information by TLC to the Darden Corporation d/b/a/ Olive Garden®, TLC will safely destroy your Personally Identifiable Information completely and will not retain any of your Personally Identifiable Information whatsoever. To fully understand your rights under the Darden Corporation's privacy policy see it at http://www.olivegarden.com/privacy-policy.

 

2.2 Non-Personally Identifiable Information


Non-Personally Identifiable Information is used as described in the Olive Garden® privacy policy and in other ways as permitted by applicable laws, including combining Non-Personally Identifiable Information with Personally Identifiable Information, as determined by Olive Garden.

3 Sharing and Disclosure of Information by TLC -

3.1 Personally Identifiable Information


TLC may share or disclose your Personally Identifiable Information in the following instances:

  • To comply with the requirements of law or comply with and legal process served on TLC, protect and defend TLC's rights or property, including the rights and property of The Reward Company, Inc. (including its affiliates or subsidiaries) or act in urgent circumstances to protect the personal safety of our end users.
  • To protect against potential fraud, TLC may verify the information collected from these Sites. Except as described in this Privacy Policy or at the time TLC requests the information, TLC does not and will not otherwise use, share or otherwise disclose your Personally Identifiable Information to any third parties.
  • To fulfill its obligations to the Olive Garden® for the purposes of the Promotion as further set forth above.
  • To provide you with information, products or services that you request from TLC or those which TLC feels may interest you but only where you have consented to be contacted for such purposes.

 

3.2 Non-Personally Identifiable Information


TLC will not collect or share any Non-Personally Identifiable Information with third parties. Such collection and sharing of any Non-Personally Identifiable Information shall be handled by Olive Garden® and subject to their privacy policy located at http://www.olivegarden.com/privacy-policy.

4 International Transfer of Information -

If you provide us with Personally Identifiable Information pursuant to your participation on the Promotion, TLC may transfer that information to its corporate parent company (including such company's affiliates and subsidiaries) or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from a country outside the UK, please note that you are transferring your Personally Identifiable Information to the UK. By providing your Personally Identifiable Information you consent to:

  • The use of your Personally Identifiable Information for the uses identified above in accordance with this Privacy Policy.
  • The transfer of your Personally Identifiable Information to the UK as indicated above.

5 Retention of Data -

When you provide any Personally Identifiable Information as part of your participation in the Promotion your Personally Identifiable Information will be stored in database for the duration of the Promotion, until TLC has fulfilled its obligations thereunder and then transferred such Personally Identifiable Information to the Daren Corporation d/b/a Olive Garden®.

 

Data and records which contain any Personally Identifiable Information will not be kept for longer than is necessary for TLC to fulfil its obligations under the Promotion. This principle finds statutory form in the Data Protection Act 1998, which requires that personal data processed for any purpose "shall not be kept for longer than is necessary for that purpose".

6 Opt-Out -

As applicable, TLC generally communicates with users who subscribe to TLC services via email. Although you may opt out of marketing messages, please note that it is in your interest to ensure that TLC is able to deliver certain non-marketing related messages and that we may be required to deliver certain notices to you by law. TLC will provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from TLC, such as emails or updates regarding new services and products offered on the Sites or if you do not want us to share your Personally Identifiable Information with third parties. The opt-out choice may be exercised by ticking or un-checking the appropriate box provided at the points where Personally Identifiable Information is collected, or by contacting us using the contact details provided at http://www.trcomarketing.com.

7 Cookies -

7.1 What are Cookies?


Cookies are small text files placed on your computer or mobile device by websites. They store preferences and other information to allow you to use the website efficiently and also provide information on how websites are used. Some cookies are essential for the website to function, others are optional. With most Internet Browsers, you can erase Cookies from your computer hard drive, block all Cookies, or receive a warning before a Cookie is stored. Further details on removing Cookies is available on www.aboutcookies.org. Please note that removing or blocking Cookies may interfere with your full use of the Sites.

 

7.2 Essential Cookies


TLC uses session cookies to store information that are essential for the Sites to function. This includes cookies that store code validation and reward information. These cookies expire when you terminate your browser session.

 

7.3 Performance Cookies


These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. TLC uses cookies to "remember" what interactions the user has had with the site and the web pages the user has viewed, for example the URL of the page.

 

We use cookies to "remember" what interactions the user has had with the site and the web pages the user has viewed, for example the URL of the page.

 

7.4 Which first party cookies does this site use?

Cookie Name Purpose Expiry
TLC Temporary .NET Sessions State ASP.NET_SessionId Used to maintain an anonymized user session by our web servers. When you leave the site, this cookie will be removed. On close of current web session
TLC Persistent Cookie Consent pop up CC_analytics Cookie Consent cookies which appear after you have clicked on the 'allow cookies' in the floating footer. More info http://silktide.com/cookieconsent 1 year from creation
Cookie Name Purpose Expiry
These cookies are used to collect information about how visitors use the Sites. TLC uses the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
AdobeAnalytics _utma Adobe stores the information collected by the cookies on servers in the United States. Adobe may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Adobe’s behalf. Adobe will not associate your IP address with any other data held by Adobe. Unless you opt-out of the Adobe Cookie, by using this site you consent to the use of the Adobe Cookie and any information generated by Adobe Analytics. 2 years
_utmb 30 minutes
_utmc On close of web session
_utmz 6 months
You can find an overview of privacy at Adobe here: http://www.adobe.com/privacy/analytics.html. For information on how to opt-out from all AdobeAnalytics cookies visit http://www.adobe.com/privacy/opt-out.html.
Cookie: TLC Temporary .NET Sessions State
Name: ASP.NET_SessionId
Purpose: Used to maintain an anonymized user session by our web servers. When you leave the site, this cookie will be removed.
Expiry: On close of current web session
Cookie: TLC Persistent Cookie Consent pop up
Name: CC_analytics
Purpose: Cookie Consent cookies which appear after you have clicked on the 'allow cookies' in the floating footer. More info http://silktide.com/cookieconsent
Expiry: 1 year from creation
These cookies are used to collect information about how visitors use the Sites. TLC uses the information to compile reports and to help us improve the Site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Cookie: AdobeAnalytics
Purpose: Adobe stores the information collected by the cookies on servers in the United States. Adobe may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Adobe’s behalf. Adobe will not associate your IP address with any other data held by Adobe. Unless you opt-out of the Adobe Cookie, by using this site you consent to the use of the Adobe Cookie and any information generated by Adobe Analytics.
Name, Expiry: _utma, 2 years
_utmb, 30 minutes
_utmc, On close of web session
_utmz, 6 months

 

7.5 Third-Party Cookies.

 

As a general rule, TLC does not use any Third party Cookies. The above list is not exhaustive and comprises the standard set of Cookies used by TLC when building a site. If you would like more information on the Cookies used by the TLC Sites (and any other site) you can do so from within your web browser visiting http://www.wikihow.com/View-Cookies

 

8 Changes to this Privacy Policy -

TLC reserves the right to change this Privacy Policy from time to time in our sole discretion. When TLC does change this Privacy Policy, then TLC shall notify of such change by revising the "Last Updated" date at the bottom of this Privacy Policy.

9 Security -

Data transmissions over the Internet cannot be guaranteed to be 100% secure. However, TLC takes all reasonable steps to ensure security of our systems and protection of the data. If TLC learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing Personally Identifiable Information to TLC you expressly agree that TLC can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. TLC may post a notice on our Sites if a security breach occurs or may send an email to you at the email address you have provided to TLC in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

10 Contacting TLC -

You have a right under the Data Protection Act 1998 upon written request and payment of a fee, to have a copy of the personal data we hold about you.

 

Please address requests for information or questions regarding this Privacy Policy to:

The Data Protection Officer
TLC Inc.
19 Harcourt Street
London
W1H 4HF

 

 

Last Update: 13 August 2015