Privacy and Cookies Policy
This Privacy and Cookies Policy (the "Policy") applies to the website (the “Website”) and the TSM App (the "App"), both of which are run by TripleStarMedia Ltd ("TSM"), whose registered office address is, Triple Ltd, 4 4 Claridge Court, Lower Kings Road, Berkhamsted, Hertfordshire, England, HP4 2AF. Company registration is 12568932
All references in this Policy to "we", "us", and "our" are to TSM.
TSM recognises the importance of honest and responsible use of your personal information, and we are committed to protecting and respecting your privacy. This Policy explains how TSM collects, uses and discloses personal information about you when you visit the Website or the App, and when you contact TSM, whether by e-mail, post, or telephone using the contact options on the Website and App. The information you provide to us through the Website and the App will initially be collected by TSM, but may then be shared with other third party company partners as set out below and to the extent that it is necessary to do so for TSM to operate effectively.
It is important to TSM that you feel completely comfortable in visiting and using the Website and the App.
For the purposes of the Data Protection Act 2018 (the "Act") and the General Data Protection Regulation 2016/679 (the "GDPR"), the data controller is TSM.
LEGAL BASIS FOR THE USE OF PERSONAL DATA
The legal basis on which TSM relies to process your personal information includes:
- On some occasions, TSM processes your data with your consent (for example, when you agree that TSM may place cookies on your device or process or share information that you input into our website).
- On other occasions, TSM processes your data when we need to do this to fulfil a contract with you (for example, if you win a prize in a competition that TSM promoted or where we are required to do this by law, e.g. to comply with record keeping obligations).
- TSM also processes your data when it is in TSM’s legitimate interests to do this, and when these interests are not overridden by your data protection rights (including, for example, when TSM shares data with our affiliates).
In most cases, the information that TSM processes about you is required to deal with your request or registration, or is required by law, or is necessary for the exercise of TSM’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure any such use is proportionate.
TSM may also convert personal information into anonymous data and use it (normally on an aggregated statistical basis) for research and analysis to improve TSM’s performance.
PERSONAL INFORMATION TSM COLLECTS FROM YOU
If you want to contact TSM or to use certain facilities we provide on the Website, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you do choose to provide TSM with your personal information, TSM will collect that information for our own use and for the purposes described in this Policy.
Where you choose to provide personal details to TSM, we may collect, store and process the following personal information from you:
- the reason for your contact, which may be an enquiry, a request or enquiry on behalf of someone else, providing a comment, or details in relation to a possible or existing competition;
- your contact and marketing preferences;
- if you take a survey or interact with us in various other ways – demographics information and information about subjects that may interest you;
- standard internet and website log information and details of patterns about how visitors behave on our Website and App. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests;
- where you “like” us or make posts on our pages on social networking websites.
This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of other company services.
USES MADE OF YOUR PERSONAL INFORMATION
TSM may use information about you for purposes described in this Policy or disclosed to you on our Website and App or with our services. For example, we may use information about you for the following purposes, all of which we believe to be in our legitimate business interests:
- to operate competitions promoted on the Website and App;
- to respond to and/or deal with any request or enquiry you may raise;
- to improve our products and services and to ensure that content on the Website and App is presented in the most effective manner for you and for your device;
- to administer the Website and App;
- for internal record keeping;
- to contact you (directly, either by TSM or through a relevant partner or agent) by e-mail or phone for the above reasons;
- subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing that you have requested;
- to perform any contract TSM has with you; for compliance with legal, regulatory and other good governance obligations and subject to your consent when entering a Competition, to share your personal data via secure transfer to any specified third party organisations that assist TSM with the operation of the Website and App.
By registering for , or via the app, and have not opted out of receiving marketing then we will send you marketing messages in relation to this site and similar products or services to those you interacted with.
- If you are currently receiving these communications and would prefer not to, you can use the 'unsubscribe', 'stop' or similar facility described in any such communication or opting out in your profile section on the site or in the app. Please note that texting STOP in response to our SMS marketing will cost one standard network rate message.
- You can stop receiving push notifications from one of our apps by turning these off at any time by adjusting the settings on your device or deleting the app from your device.
If you agree that we can pass data to third party for their marketing purposes, you’ll need to contact the applicable third party to opt-out of receiving communications from that third party. Please note that we are not responsible for the communications you receive from any such third party.
DISCLOSURE OF YOUR PERSONAL INFORMATION
Your personal information will be made available for the purposes mentioned above (or as otherwise notified to you from time to time), on a 'need-to-know' basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other TSM staff who properly need to know these details for their functions within TSM. Please note that certain individuals who will see your personal information may not be based at TSM or in your country of residence (please see below).
We may share personal information within TSM as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by TSM for the other purposes described in this Policy.
Your personal information may also be made available to third parties (within or outside TSM) providing relevant services under contract to TSM (see below for further details), such as credit and debit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. Subject to your consent when entering a Competition, TSM may also share your personal data via secure transfer to any specified third party organisations that TSM has contracted with in order to operate the Website and App, and the Competitions contained therein. Those organisations will process that data for their own respective purposes, and will become the controller of that personal data. TSM has put in place various security and data privacy measures, inclusive in scope of such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.
Specific third party partners that TSM may share your personal information in relation to the operation of the Website and App under contract and in accordance with the paragraph above include the following:
- Arama Software Limited (Registered Address at 1D, 1st Floor, Felicity Building, 38 Peel Street, Central, Hong Kong)
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA that work for us or for one of our providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We will not sell your personal information to any third party other than as part of any restructuring of TSM or sale of the business.
TSM may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services and products (the “Purpose”).
TSM may also use such reviews in other promotional material and media for our advertising and promotional purposes.
WHAT CHOICES DOES TSM OFFER YOU WITH REGARD TO DIRECT MARKETING?
TSM may wish to provide you with information about new products, services, promotions and offers which may be of interest to you, and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post, social media or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.
WHAT SAFEGUARDS ARE IN PLACE TO PROTECT YOUR PERSONAL INFORMATION?
TSM takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of TSM, or our agents.
WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND YOUR PERSONAL INFORMATION?
You have the right to review and access your personal information held by TSM.
You also have the right to ask us to rectify, block, complete and delete your personal information, to restrict its use, and to 'port' your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).
In addition, you have the right to request further information about the handling of your personal information.
If you wish to do so, or to notify TSM of a change in your details, please contact and/or post to TSM Ltd, 4 4 Claridge Court, Lower Kings Road, Berkhamsted, Hertfordshire, England, HP4 2AF.
There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person, or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process and store your data.
If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to the data protection authorities.
KEEPING YOU INFORMED
When we store your information, we do so for as long as necessary to (i) fulfil the specific purposes set out in this notice for which your personal information was collected and (ii) to comply with our legal obligations or enforce our legal rights.
CHANGES TO THIS PRIVACY AND COOKIES POLICY
We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Website or App for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.