This website and the Smiley Card are part of the Smiley rewards program, which is owned and/or operated by TBS Group, Cochin. This privacy statement has been created in order to disseminate our firm commitment to the privacy of our Cardholders. The following statement discloses our information-gathering and dissemination practices on www.smileycard.in and for the Smiley Cardholders and across the Network of which these two services are a part.
To ensure that the offers and services are relevant we may solicit information from the members from time to time. This is solely for the purpose of making the program more and more meaningful. We are committed to protecting the privacy of our members and their transactions. This section explains how we protect and use your information in safe, secure and responsible manner. We value your privacy.
The Information We Gather
How We Use and Disclose Your Information
Choice/Opt-out
Improper Conduct
Your Consent
Contacting Us
1. The Information We Gather
Registration Information -- To process your application for a Smiley Card, or to register your Smiley Card online, we require users to give us contact information (like their name, street address and e-mail address), demographic information (like their state, zip code, birth date, gender, ), and payment information . We may share certain of your information with third parties who issue or manufacture the Smiley cards as needed. We also use your information to send you information about our company and promotional material on behalf of our partners, to notify winners of sweepstakes or contests, and to contact you when necessary. You may opt out of receiving future mailings; see the choice/opt-out section below.
Transaction Information - We may continually gather data concerning your transactions with us, our partners or others. This information may include your Smiley Card usage and other information. We use this data to provide you with better information, discounts and other offerings across our Network and from third parties.
Surveys -- Surveys on our Network ask visitors for contact information (like their e-mail address). We use contact data from our surveys to send users confirmation of having successfully submitted the survey, information about our company and promotional material on behalf of our partners. The customer's contact information is also used to contact the visitor when necessary. Users may opt-out of receiving future mailings; see the choice/opt-out section below.
Contests/Promotions -- We run contests on our Program in which we ask visitors for contact information (like their e-mail address). We use contact data from our contests to send users confirmation of having successfully entered the contest, to notify the winners of contests, and send information about our company and promotional material on behalf of our partners. The customer's contact information is also used to contact the visitor when necessary. Users may opt-out of receiving future mailings; see the choice/opt-out section below.
Co-branded Cardholder Applications and Offers -- In order to receive special offers from certain of our partners that are identified by name ("Co-Branded Partners"), you may be asked to provide additional personally identifiable information. Information submitted in conjunction with an offer made by a Co-Branded Partner may be shared with the Co-Branded Partner, in which case the Co-Branded Partners' use of such information will be governed by the privacy policy of that particular Co-Branded Partner. Check the Co-Branded Partner's site for specifics. If you do not wish the Co-Branded partner to receive your information, then you may simply decline to receive the special offer. You are not required to respond to any special offer and it is always at your option.
Prospect Information -- Our Program also collects prospect information from our users. Our users may provide another person's information, such as their friend's e-mail address, in order to send them content or offerings from our Network. The prospect's information is only used for the purpose for which it was submitted. This prospect information will never be shared with third party advertisers. We will never sell or release the prospect information to anyone, except when required by law. Prospects may opt-out of receiving future mailings; see the choice/opt-out section below.
All the above information is collected for:
•better servicing of the members and preparing quarterly statements and account maintenance.
•making the offerings more relevant to the members and as desired by them ensuring no spam mails go through.
•keeping track of point transactions, of help in case of any dispute situations.
To collect the above information we shall use channels such as physical forms, call centre, website (cookies etc) and emails, promotional offers, surveys, sweepstakes. Participation in these promotions is optional but you may be required to provide your personal identification information in order to participate.
From time to time we shall ask the members to update their contact & personal information with the program. This is to help keep you updated on any program changes and enhancements. We shall not be liable for any failure to notify you of program changes if you fail to update such information in a timely manner.
We do not provide or share information collected to any companies other than our group companies or business partners, to market their products unless you authorize us to do so. Even when you do so, these companies are not allowed to use this information for purposes beyond your specific authorization. Even when we do share the data it is mostly in aggregate form and no individual data is shared.
In some situations, however, we are required to or we may provide all information we collect about you to third parties outside our group companies, including financial or non-financial companies as permitted by law, such as, with your consent:
•to respond to judicial process, regulatory authorities or law enforcement agencies; or
•to consumer reporting agencies; or
•in connection with a proposed or actual sale, merger, or transfer of all or portion of business; or
•to protect against fraud, money laundering or other risks.
some of the data may have to be provided to third party services for the sole purpose of implementing marketing services on behalf of smiley and/or group companies and for providing customer support services like sending statements
2. How We Use and Disclose Your Information
We use your information to deliver personalized services, content, discounts and advertisements to enhance your experience with us. For example, we may send you and e-mail/SMS with a special offer or discount from one of our affiliates, divisions or participating sponsors on Spring Break travel because you selected "travel" as an area of interest under your personal profile when you registered to use a site on the Program.
We do not provide your personally identifiable information to third parties or mass marketers without your consent. For example, we will not provide another company your name or e-mail address without your consent. Unless you consent to the disclosure of your personally identifiable information, only we and our affiliates, our technical consultants, third party auditors and other third parties who make our site available, enhance its functionality, or provide associated services and/or who deal with you in delivering content, samples, products, and gifts and prizes, have access to this information, and we require them to agree that they are covered by this policy. Please note that we do reserve the right to transfer your personally identifiable information and other information that you have provided to us to our successors in business and purchasers of our site assets.
We reserve the right, without disclosing your personally identifiable information to third parties, to use the information you provide to offer you additional Smiley or third party products and services that we think will be of interest to you. If you respond to such an offer and contact a third party directly, that third party's privacy policy will apply to any information you provide and/or that is collected by such third party and we are not responsible for that party's use of your information. Similarly, as noted above, information submitted in conjunction with an offer made by a Co-Branded Partner may be shared with the Co-Branded Partner, in which case the Co-Branded Partners' use of such information will be governed by the privacy policy of that particular Co-Branded Partner and we are not responsible for that party's use of your information. In addition, on occasion, we may ask for your consent to share particular data with a third party. This is always at your option and is not required.
We also do disclose aggregated data to our advertisers and Co-Branded Partners and other third parties to generate reports, marketing and technical research and for related business purposes. Our advertisers allow us to provide our service to you. In return, they need to know how to effectively place their ads to potential customers. For example, we tell advertisers how many people saw or clicked on an ad and additionally, how many people saw or clicked on ads in different portions of our service. Where available, we may offer additional information about viewer characteristics. However, this does not include personally identifiable information about you or your online usage patterns.
We will use these updates to provide you with additional discounts, special offers, site upgrades, new features, events, promotions, and much more. You have the option to opt out of receiving mobile phone communications by e-mailing Card Services or changing the preferences on your account.
We participate in programs where certain companies ("Participating Companies") direct users to our Program or provide certain incentives or benefits to our users. If you are directed to a service in our Program by such a program (a "Participating Company Program") and you provide or we collect personally identifiable information or non-personally identifiable information in connection with the Participating Company Program, we may share this information with other parties that are participants in the Participating Company Program or that administer the Participating Company Program. For example, if you come to a site on our Program as a referral from an online affiliate user, we may have a contractual obligation to make payments to and send certain corresponding information to the affiliate user that linked you to us and to a separate entity, if any, that administers the affiliate program. Similarly, when you use your Smiley card at any merchant or sponsor, we may provide any or all of your information to that merchant or sponsor.
Information obtained in connection with any service on the Program may be intermingled with and used by us in conjunction with information obtained through sources other than that service, including both offline and online sources, both on and off the Program.
3. Choice/Opt-out
You have the option to sign up for free e-mail updates and/or mobile phone messages when you apply for a Smiley Card. You will also have the option to opt out of receiving the updates. The e-mail opt-out messaging will appear at the bottom of every e-mail that is sent out to you. Mobile phone opt-outs requests should be sent to Card Services via e-mail. You can also opt-out of both email and mobile phone communications by changing your account preferences online.
4. Improper Conduct
The restrictions above will not apply in the event that you engage in certain improper conduct. Specifically, TBS Group shall have the right to itself use or release to third parties personally identifiable information regarding users who are suspected of having used any site or any other service in the Network for any fraudulent purposes or having otherwise violated any law, rule or regulation or the rights of third parties or having engaged in any conduct which Smiley Program deems improper. By using any service in the Program, you are agreeing to our use or release of any information you provide in any manner we deem appropriate or necessary if you are suspected of having engaged in any conduct which Smiley program deems improper.
5. Your Consent
By using any web site or other service in the Network, you consent to the collection, use, and storage of your personal and non-personal information as described above. You also authorize the export of personal information and its storage and use as specified above when you provide such information to us.
We may amend our Privacy Policy, but if we decide to change our Privacy Policy, we will post those changes on this page, so you can always be aware of what information we collect, how we use it and under what circumstances we may disclose it. Any changes will only apply to information collected after the change is posted.
6. Contacting Us
If you have any questions about this privacy statement, the practices of the Network, or your dealings with the Network, you can e-mail us at mail@smileycard.in, or send mail to us at Smiley Reward Program, TBS Group, LFC Cross road, Kaloor, Cochin-682017.
