December 7, 2011
1. Types of Information We Collect
We collect the following types of information (“Personal Information”) about you:
Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of TBF.
Relationship Information that helps us to understand who you are and what types of relationships that would be a good fit for you (Mentoring, Partnering, etc). This includes location information related to your state/province, city, or neighborhood; areas of interest such as the conditions or charities you follow, the types of deals that interest you, information collected from social media interactions (such as via Facebook Connect); demographic information (e.g., birth date, age, gender); information about merchants for whom you have purchased TBF offers from; and information about associates who refer you or who you have referred.
Transaction Information about how you interact with TBF, such as the TBF offers you purchase and redeem, your interactions with merchants, business partners, and service providers, and other information about how you use TBF sites, programs, and applications.
Financial Account Information needed to process payments for TBF membership or things you purchase via the site, such as your credit or debit card number, expiration date, and card verification number.
Mobile Location Information to help us offer you real-time deals nearby, if you have activated one of our mobile applications and permitted your mobile or other location-aware device to transmit location data.
2. How We Collect Information About You
We collect Personal Information in a number of ways, including the following:
Registration. When you sign up for TBF, you are required to provide your email, profileID, first and last name and birthday.
Your actions within TBF. We receive data about you when you take actions within TBF such as visiting the site, posting an update, uploading a photo, commenting on a friend's post, adding a friend, following a celebrity or charity, looking at another user’s profile, searching for a friend or a Page, clicking on an ad, purchasing an offer, or indicating that you are in a relationship.
Your files. When you post things like photos or videos on TBF, we may receive additional related data (or metadata), such as the time, date, and place you took the photo or video.
Your associates. We receive data about you from the actions of your associates, such as when your associate tags you in a picture or when you respond to a post made by one of your associates.
Your feedback and support requests. When you contact us with feedback or customer support requests, we collect information including your method of contact and the content of your request in order to improve your TBF experience and address your question.
Your interactions with third parties. Sometimes we get data from our advertising partners, customers and other third parties that helps us (or them) deliver ads, understand online activity, and generally make TBF better. For example, an advertiser may tell us how you responded to an ad on TBF or on another site in order to measure the effectiveness of - and improve the quality of - those ads. We may also receive information about you from the challenges, health logs, applications, and external websites you use, but only when you have given them permission. The default settings for all information is set to be shared with all merchants and partners. Please see “Your Choices” below for instructions on changing these default settings.
We may also receive general information or Personal Information from third parties including our parent company and affiliates, including aggregated data that we use to influence the product recommendations that you receive.
If you use a social media platform or your mobile device (or other method of communication) to interact with TBF, the application may have a specific privacy statement that governs the use of Personal Information related to that application. For example, if you use a TBF mobile application and your mobile device’s settings allow it, we may collect Mobile Location Information from your device. Please consult your application’s or your device’s settings and privacy policies to determine how to change your settings and restrict the information collected about you.
3. How We Use the Information We Collect
We use Personal Information in the following ways:
to operate and improve our Site and Services;
as part of our efforts to keep TBF safe and secure;
to provide you with relevant offers and advertisements and to measure or understand the effectiveness of advertisements you and others see;
to provide you with location features and services, like telling you and your associates when a special offer is available in a location nearby;
to make suggestions to you and other users on TBF, such as suggesting offers you may be interested in, suggesting that another user add you as a friend because the other user imported the same email address as you did, or suggesting that a friend tag you in a picture by comparing your friend’s pictures to the photos you have been tagged in;
to communicate and provide additional information that may be of interest to you about TBF and our merchants and business partners, such as newsletters, special offers and coupons, announcements, updates, security alerts, support and administrative messages, and marketing materials;
to facilitate orders and the administration of offers;
to provide customer support, including to our merchants or business partners;
to track use of the Site and Services and perform analytics;
to send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins; and
to manage our everyday business needs such as website administration, blog, FAQ and forum management, provisioning, analytics, and fraud prevention, or to comply with the law.
Our use of the information we collect as described in this Privacy Statement not only allows us to provide TBF as it exists today, but it also allows us to provide you with innovative features and services we develop in the future that use the information we receive about you in new ways.
4. When and Why We Disclose Personal Information
We will not disclose your Personal Information to third parties except to:
Affiliated companies (e.g., subsidiaries and other companies owned by or controlled by TBF) who may only use the Personal Information for the purposes described in Section 3 above. Will we not share personal information with merchants or retailers?
Our service providers that provide services for us such as sending emails on our behalf and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them.
Merchants, but only to the extent you have purchased or redeemed a TBF offer from a participating merchant, or participated in an offer, challenge or other activity sponsored or offered through TBF on behalf of the merchant. We may also provide merchants with Personal Information about the individuals who have purchased the merchants’ TBF offers, to send customized offers, to validate the purchases, to aid and troubleshoot redemption, to combat fraud and to facilitate a direct relationship between merchants and customers and enable merchants to communicate electronically with customers who purchased TBF offers.
TBF business partners or advertisers, as part of an offer, challenge, contest, or other activity that is provided by or in conjunction with TBF and its business partners and in which you have elected to participate. For example, if you are referred to TBF from a business partner's website or through an invitation facilitated by or in conjunction with a TBF business partner, TBF may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between TBF and the business partner, which may allow such business partner to contact you directly and to advertise to you.
Effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate. If TBF is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on the TBF website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
We encourage TBF Merchants and business partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control. You can choose not to share your Personal Information with Merchants and business partners by not participating in certain challenges, offers, or other interactions involving those Merchants and business partners.
We do not disclose Personal Information to Merchants from whom you have not purchased an offer. When a merchant submits an offer on TBF, it is given the opportunity to choose consumer prospects by criteria including location, demographics, celebrities or charities followed, types of challenges participated in, and types of products purchased in the past. We distribute offers to the people who meet the criteria the merchant selected, but do not disclose the identities of those people. After the offer campaign is over, we provide merchants with reports on how their offers performed, including how many users saw or clicked on their offers. These reports are anonymous. We do not tell merchants who saw or clicked on their offers.
We may disclose information about you that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.
Certain information about you is public, including information you or your associates choose to make public and your name, profile picture and profile ID. Public information may be associated with you even outside of TBF, and can show up when someone searches on a public search engine or on TBF. Your public information helps associates recognize you and is accessible at http://www.jointbf.com/profile/username. If you are uncomfortable sharing any of this public information, you may delete or deactivate your account as described below.
Your trust is important to us, which is why we don't share information we receive about you with others unless we have:
received your permission;
given you notice, such as by telling you about it in this policy; or
removed your name or any other personally identifying information from it.
5. Cookies and Related Technologies
When you use TBF, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs.
A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of TBF. Cookies help us to provide a customized experience by allowing us to recognize you when you return, and to track and target your interests.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about TBF users to optimize and understand the site’s traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Statement governs how we use that information.
6. Your Choices
We think that you benefit from a more personalized experience when we know more about you and the kinds of deals you like. However, you can limit the information you provide to TBF or its advertisers or merchants, and you can limit the communications that TBF or third parties through TBF send to you.
You can manage your email preferences by logging into your account through the Sites, entering the “Settings” section, and selecting “Notifications.” From here, you may choose to subscribe or unsubscribe from certain types of offers or promotional messages. You may update your subscription preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases. For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you purchase TBF offer.
In addition to the above, you can opt-out of being targeted by certain third party advertising companies online at www.networkadvertising.org/consumer/opt_out.asp or http://preferences.truste.com/truste/. If you wish to opt out of receiving offers directly from TBF merchants or business partners, you can follow the opt-out instructions in the emails that they send you.
You can control whether we suggest that another user tag you in a photo using the “Settings” area.
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.
You may manage how your mobile device and mobile browser share Location Information with TBF, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
You may also manage the sharing of certain Personal Information with us when you connect with us through a social media platform or application, such as through Facebook Connect. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between TBF and your social media account or your mobile device.
Other than the choices listed in this section, you cannot opt out of the use of your Personal Information as described in this Privacy Statement. If you do not want TBF or its affiliates, merchants and advertisers to use your Personal Information as described in this Privacy Statement, delete your account and do not use the Site or Services.
7. Deleting and deactivating your account
If you want to stop using your account, you can submit a request to delete your account. We will process your request within 48 business hours and send notification to email on record that your account has been deleted; it is permanently deleted from TBF. It will be deleted, but some information may remain in backup copies and logs for up to 90 days. You should only request that your account be deleted if you are sure you never want to reactivate it.
8. Accessing and Correcting Personal Information
Keeping Personal Information about you current helps ensure that we offer you the best deals available through our merchants and business partners. You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information, and the other information you provided to use in your profile by logging into your account and accessing the “Settings” section of the Site or sending us an email at privacy@joinTBF.com.
If you want to close your account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, closing your account, and removing your active profile, we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous purchases on TBF for financial reporting and compliance reasons.
9. Security of Personal Information
TBF has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. For example, we use industry-standard encryption technology to secure Financial Account Information when it is being transmitted over the Internet
10. Privacy Practices of Third Parties
This Privacy Statement only addresses the use and disclosure of information by TBF through your interaction with our site. Other websites that may be accessible through links from TBF may have their own privacy statements and personal information collection, use, and disclosure practices. Our merchants and business partners may have their own privacy statements, too. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of an offer or promotion.
TBF has relationships with third party advertising companies to place advertisements on our behalf onto other websites, and to perform tracking and reporting functions for our Sites and our advertisements. We do not share Personal Information with third party advertising companies; however, these third parties may collect information about you on their own, for example by using cookies and other tracking technologies. This Privacy Statement does not cover the privacy practices of these third parties, and TBF is not responsible for them. We encourage you to review the privacy policies or statements of these third party advertising companies. If you would like more information about the practices of third party advertisers and your choices about not having your information collected or used by third party advertisers, please visit http://www.networkadvertising.org/opt_out.asp.
11. Minors and safety
We take safety issues very seriously, especially with children, and we encourage parents to teach their children about safe internet practices. To create an account on TBF, you must be at least 13 years of age. This restriction is enforced by the birthday requirement in the profile. It is not required to create an account, but if the birthday is not provided after 7 days, the account will be deactivated until is it provided.
12. Notice to Residents of Countries outside the United States of America
TBF Global Ventures, LLC. is headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to our Privacy Statement, regardless of where it is processed or stored.
13. Facebook Connect
If you are not currently registered as a TBF user and you use the Site’s Facebook connection functions, you will first be asked to enter your Facebook credentials and then be given the option to register and join TBF. Once you register with TBF and connect with Facebook, you will be able to automatically post recent TBF activity back to your Facebook wall. Please refer to the privacy settings in your Facebook account to manage the performance of your Facebook account.
14. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement to clarify our practices or to reflect new or different privacy practices, such as when we add new features to our Sites. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information about our privacy practices.
15. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by TBF pursuant to Section 1798.83 of the California Civil Code, please contact us via email to privacy@joinTBF.com, or by writing us at the following address:
TBF Global Ventures, LLC
Attention: Privacy Office
4500 S Four Mile Run Dr. Apt 1230
Arlington, VA 22204
Please allow 30 days for a response.
16. Privacy Concerns
[For general questions and concerns about your privacy as a TBF user, please email us at privacy@joinTBF.com]