FOR TFC APP USER
Information for individuals who are or were customer or visitor and/or user of TFC digital
application. This notice sets out what personal data we collect, for what purposes and your rights in
What does this Privacy Notice cover?
This Privacy Notice provides information regarding the processing of your personal data when using
services and/or purchasing products from TFC B.V.
The privacy statement may contain further information about how TFC B.V. is processing your
personal data. This would be the case if you are TFC-customer.
This Privacy Notice explains what personal data are processed about you; why we are processing
your personal data and for which purposes; for how long we hold your personal data for; how to
access and update your personal data, as well as the options you have regarding your personal data
and where to go for further information.
This section describes the different sources from which we collect your personal data.
What personal data do we process about you? Collection of information
We collect information, including personal data about you, as a TFC-customer, user of TFC App. This
information may be either:
• Information that you provide to us – when creating a TFC-account, we will ask for your
name, e-mail address and gender (so that we can address you properly but you do not have
to provide us with this information), your contact preferences and information necessary for
answering any security questions. If you decide to become a TFC-customer and user of TFC
App we may ask you to provide further personal data necessary for the performance of such
services and/or authentication such as type of vehicle, driver pattern, date of birth (if
collected), communications preferences and mobile number;
• Information that we obtain – we will also collect information about how and where you use
or purchase TFC-services and products. Such information may include electronic device
information, IP addresses, log information, browser type and preferences, location
information, online identifiers to enable ‘cookies’ and similar technologies. Your purchase
history includes data regarding (i) specific products you buy, (ii) the total amount of your
purchases per transaction, (iii) the time and place of the purchases you make and (iv) the
payment method you use, including payment methods embedded in the TFC App (such as
mobile payment option in the future);
• Information gathered through external sources – in order to ensure we have the most up to
date information about you to provide you with better products and increasingly tailored
services, we will combine information that we hold about you, with additional information
which is publicly available;
• Information gathered through social media pages – When you communicate with us
through a TFC Social Media Page (for example, when you comment on, share or react to a
post, upload media, send a personal message or subscribe to a TFC Social Media Page), we
may receive personal data about you such as your username, profile picture, hometown,
email address and gender. We will use any personal data received from social media in
accordance with this Privacy Notice.
TFC view of the customer
With the aim of ensuring you have a seamless experience with TFC B.V., and depending upon the
nature of your engagement with TFC B.V., we combine information gathered from the sources
referred to above to create a personal profile of you. This enables you to interact with TFC B.V. more
easily and ensures we have the most up to date information about you in order to better develop
services and products and to tailor offers relevant to your specific interests.
Please note however, you have the ability to control how TFC B.V. uses this information. You can opt
out of having your personal data combined in this way. We only process your personal data where
we have a lawful basis to do so.
Why do we process your personal data?
The personal data covered by this Privacy Notice are only processed:
• with your explicit consent;
• where it is necessary to conclude a transaction with you (such as payment information);
• where it is necessary for the purposes of the legitimate interests pursued by TFC B.V.,
except where such interests are overridden by your interests or fundamental rights and
• where it is necessary for TFC B.V. to comply with a legal obligation.
Where the processing is based on consent, you have the right to withdraw your consent at any time.
This will not affect the validity of the processing prior to the withdrawal of consent.
What are the consequences of not providing your personal data?
Where you choose not to provide us with information set out above for the purposes of using TFC
App the only consequence is that it will affect your ability to fully interact with the TFC App.
Who is responsible for any personal data collected?
Depending upon your location, TFC B.V. will be responsible for processing your personal data.
The purposes for which we process your personal data.
For what purposes do we process your personal data?
We process your personal data for the purposes of:
• provide our products and deliver our services to you;
• managing relationships and marketing such as maintaining and promoting contact with you;
• account management including account verification (that is, ensuring that only you or
someone you have authorized can access your account and information);
• customer service and development of our products and services;
• performance of and analysis of market surveys and marketing strategies;
• promotions and contests offered to TFC-customers.
• detecting or preventing fraud if you use a mobile payment function in the future to purchase
or for a secondary purpose where it is closely related, such as:
• storing, deleting or anonymising your personal data;
• audits, investigations, dispute resolution or insurance purposes, litigation or defence of
• statistical, historical or scientific research; or
• legal and/or regulatory compliance.
Communication and marketing – your choices
If you have consented to receive communications from TFC B.V. (or if you have previously purchased
services from us ), you may receive offers that are tailored towards your preferences based on the
information gathered about you, described above, in order to provide you with better products and
increasingly tailored services.
We may send you service updates and notifications without your advance consent only where such
updates and/or notifications are necessary for the proper functioning of TFC App or other services
that you use.
You may receive pertinent offers and communications by different channels and you may update
your subscription preferences via your personal profile settings anytime or use the unsubscribe
functionality for the different digital channels.
Transaction security and preventing, detecting and investigating fraud
When you use a mobile payment application in the future to purchase TFC-services, you may be
asked to provide additional personal details to complete the transaction. We may use the personal
data you provide to prevent, detect and investigate fraud and to enforce the terms and conditions of
the mobile payment application in the future.
We may share some information with the service providers involved in mobile payments in the
future, including but not limited to your IP address, device ID or unique identifier, TFC card number
for the purposes detailed above as well as for the purposes of device type, geo-location information,
connection information (for e.g. wi-fi) and mobile network information.
Your rights and how to exercise them.
Your rights in relation to your personal data
We aim to keep our information as accurate as possible. You can request:
• access to your personal data;
• correction or deletion of your personal data (but only where it is no longer required for a
legitimate business purpose such as completing a transaction);
• that you no longer receive marketing communications;
• that the processing of your personal data is restricted;
• combining of your personal data from different sources to create a personal profile no
longer takes place; and/or
• that you receive personal data that you have provided to TFC B.V. in a structured, digital
form to be transmitted to another party, if this is technically feasible.
To make any of these requests please go to your TF-account in your personal portal, My TFC or
please contact us at firstname.lastname@example.org in this respect.
Who can you contact if you have a query, concern or complaint about your personal data?
If you have any issues, queries or complaints regarding the processing of your personal data, please
contact us at email@example.com for further information or for submitting such requests.
Cookies and similar technologies
TFC Website or use TFC App. This is to enable TFC to identify your internet browser and collect data
on your use of our website, which pages you visit, the duration of your visits and identify these when
you return so that we improve your experience when visiting our website. You can control and
manage your cookies preferences by adjusting your browser settings.
TFC B.V. is committed to safeguarding your personal data.
Security of your personal data
We have implemented technology and policies with the objective of protecting your privacy from
unauthorised access and improper use. In particular, we may use encryption for some of our
services, we apply authentication and verification process for access to Shell services and we
regularly test, assess and evaluate the effectiveness of our security measures.
Who will we share your personal data with?
Your personal data are exclusively processed for the purposes referred to above and will only be
shared on a strict need to know basis with:
• With your consent, authorized companies in co-operation with TFC B.V. that may supply
services to users of TFC App;
• Authorized service providers involved in mobile payments in the future;
• Authorised agents, licensees, service providers and/or external auditors;
• A competent public authority, government, regulatory, supervisory, investigative or fiscal
agency where it is necessary to comply with a legal or regulatory obligation to which TFC
B.V. is subject to or as permitted by applicable law; or
• Any person to whom TFC B.V. proposes to transfer any of its rights and/or duties.
Your personal data may be transferred outside of your country, subject to appropriate safe.
Transfers of your personal data to other countries.
Where your personal data have been transferred to companies within TFC B.V. and/or to authorized
third parties located outside of your country we take organizational, contractual and legal measures
to ensure that your personal data are exclusively processed for the purposes mentioned above and
that adequate levels of protection have been implemented to safeguard your personal data. These
measures for transfers among TFC B.V. in the European Union, European Commission approved
transfer mechanisms for transfers to third parties as well as any additional local legal requirements.
Interacting with TFC through social media.
If you choose to interact with TFC through social media on a TFC administered social media page
such as Facebook, Instagram, Twitter or LinkedIn, your personal data (such as your name, your
profile picture and the fact that you are interested in TFC) will be visible to all visitors of your
personal webpage depending on your privacy settings on the relevant social media platform, and
will also be visible to TFC B.V. You can delete any information that you share on these sites at any
time through your relevant social media platform’s account. TFC does not track your activity across
the different social media sites that you use.
Additionally and to the extent TFC B.V. is jointly responsible with a social media platform and will
have access through the social media platform to aggregated data providing statistics and insights
that help to understand the types of actions you take on TFC Social Media Pages. For more
information on how your personal data are processed on those social media platforms, including any
targeted advertising that you may receive, please refer to your privacy settings accessible through
your relevant social media platform’s account.
How long do we hold your personal data for?
Personal data processed by TFC B.V. in line with this Privacy Notice will be deleted or rendered
anonymous (such that it will no longer be possible to identify you);
1. every 5 years where you remain a customer during this period;
2. without undue delay upon you requesting that your TFC-account is deleted;
3. after 3 years for all subscribed services from our last interaction with you (that is where you
have not used our services for 3 years).
In relation to financial transactions (including those made through TFC App in the future), your
personal data will be held for 7 years from the transaction.
In all cases information may be held for (a) a longer period of time where there is a legal or
regulatory reason to do so (in which case it will be deleted once no longer required for the legal or
regulatory purpose) or (b) a shorter period where the individual objects to the processing of their
personal data and there is no longer a legitimate business purpose to retain it.
This Privacy Notice will be updated over time.
You are advised to regularly review this Privacy Notice for possible changes.