Privacy Policy

Who we are

TFC International Ltd. provides reward and loyalty program services for businesses around the world who want to recognize their clients, employees, partners, or anyone with a wide variety of instantly redeemable eGifts.

Clients can use our service on thefirstclub.com or through a Brand-customized version of the solution in a variety of ways: redeeming rewards which have been awarded to employees or customers; offer a gift to someone else and earn and collect points to get gifts with larger values.

What personal data we collect and why we collect it

We collect limited information to provide a better user experience – from figuring out basic stuff such as which language you speak, to more complex things such as which country you are in, so we only give you access to the rewards available in your Country. The information TFC International Ltd. collects is strictly for the performance of the service now and in the future.

When you are not signed in to a TFC International Ltd. Account, we store the information that we collect with unique identifiers tied to the browser, application or device that you’re using. This helps us do things such as maintain your language preferences across browsing sessions.

(a) Information we collect as you use our services:

We collect information about the apps, browsers and devices that you use to access our services, which helps us provide features such as recommendations on new rewards.

The information that we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information and application version number. We also collect information about the interaction of your apps, browsers and devices with our services, including IP address and the date, time of your request.

We collect this information when your apps, browsers and devices contact our servers, but they are not connected to your personal information.

(b) Your activity

We collect information about your activity on our services, which we use to do things like recommend a reward that you might like or provide customer service for the items you’ve redeemed. The activity information that we collect may include:

(i)   Your first and last name

(ii) Your address

(iii) What you search for

(iv) Pages you visited

(v) Reward pages

(vi) Redemption activity

We use the information that we collect from all our services for the following purposes:

(a) Provide our services

We use your information to deliver our services.

(b) Maintain & improve our services

We use the information we collect to make improvements to our services – for example, understanding how your redemption experience was so we can make it smother.

(c) Provide personalised services

We use the information we collect to customise our services for you, including providing recommendations and personalisation.

(d) Measure performance

We use data for analytics and measurement to understand how our service is used. For example, we analyse data about your visits to our sites to do things like optimise service design. We use a variety of tools to do this, including Google Analytics.

(e) Interact with you

We use information that we collect, such as your email address, to communicate with you directly. For example, we may send you a notification to let you know about upcoming changes or improvements to our services, confirmation of content redeemed and answer customer service questions.

(f)  Protect our users

We use information to help improve the safety and reliability of our services. This includes detecting, preventing, and responding to fraud and abuse, security risks and technical issues that could harm TFC International Ltd, our clients and our users. For some transactions you perform on our service, we use an external service provided by Threatmetrix to evaluate the risk around this transaction and make sure you are the person performing the transaction on your account. Risk evaluation data are deleted after six months.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

 

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

 

Who we share your data with

Our services let you share information with other services or people, with your consent. Each time this will happen you will be prompted with information about the service before asking you to agree to it. For example, when you redeem an eMagazine we will ask you the email you use or will use for registering to the account with our partner Zinio. Storing that information will only allow us to ease the redemption process moving forward and not ask the same question twice. Your data stored by Zinio and our other content partners are regulated by their data policy. All the partners we work with comply with GDPR, so you can expect the same level of protection we offer you directly.

Should you post messages on our community, the information contained in your posting will be stored on our servers and will be openly available by other users on the platform.

We may share personal information outside TFC International Ltd. if we believe the disclosure of the information is necessary to:

(a) Meet any applicable law, regulation, legal process or enforceable governmental request

(b) Enforce applicable Terms of Service

(c) Detect, prevent or otherwise address fraud, security or technical issues

(d) Protect against harm to the rights of the right holder we work with as required or permitted by law

We may share non-personally identifiable information with our clients and partners to – for example – show trends about the general use of our service.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

We currently store all your personal data with Salesforce.com on servers located in the United States. We also backup your data from Salesforce.com into two other online storage services also located in the US. Data protection laws vary among countries, with some providing more protection than others. Currently as the European data protection laws provide the best protection to the user, we have decided to provide all our users on a worldwide basis all rights specified in the GDPR laws, such as the right for you to request access to, update, remove, and restrict the processing of your information. TFC International Ltd, fully complies with the GDPR (General Data Protection Regulation).

The European Commission has determined that certain countries outside of the European Economic Area (EEA) like the United States, adequately protect personal data. To transfer data from the EEA to other countries, such as the United States, Salesforce.com and our two other online storage services must comply with legal frameworks that establish an equivalent level of protection with EU law.

The following link provide you access to Salesforce’s Notice of Certification Under the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework.

Your contact information

 

Additional information

How we protect your data

Our service is built with strong security features that continuously protect your information. It’s our commitment that all of your personal data is encrypted before being stored. We partner with Salesforce.com for this storage so you benefit from their security features as well.

What data breach procedures we have in place

 

What third parties we receive data from

 

What automated decision making and/or profiling we do with user data

 

Industry regulatory disclosure requirements