Travelex Privacy Statement

Information you give us

You give us information about yourself when you purchase or use Travelex Services or partner branded services.
For example, when you:

• communicate with us (in writing, by phone, via social media or by any other means),
• enter into any of our competitions, promotions or surveys,
• sign up for marketing communications or register for loyalty schemes offered by us.
• use our app.
• If you purchase any Travelex Services, we will collect information from you that will enable us to complete your transaction.

Information we collect automatically

Travelex also collects certain information about you by automated means, such as cookies if you opt into receiving them, when you visit our Sites, or when you use the Travelex Services or app.

• When you download our mobile app or access our services from a mobile device we may collect personal information from you such as, your name, email address, username, password, mobile device information and system (for example android or IOS), and your geo-location.
• Dependant on your marketing and cookies preferences and your geo-location settings, we may present and display to you in the app targeted marketing and advertising messages or collect information about how you use the app in order to improve app performance and our digital online services.
• We use the information we collect automatically:
  • to administer our Sites for internal operations like troubleshooting;
  • to ensure that content from our Sites is presented in the most effective manner for you and your devices;
  • as part of our effort to keep your information and our Sites safe and secure
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and 
  • to make suggestions and recommendations to you and other users of our Sites about goods or services that may interest you or them.
  • to establish communication that allows you to give feedback and/or reviews on Travelex services.
  • When you visit our premises such as at our bureaux de change stores and ATMs , we may collect CCTV images of you for the prevention and detection of crime and public safety.

Information we receive from third parties

• We also receive information from third parties (including publicly available information). This information includes:
  • Information about you from other members of the Travelex Group Companies,
  • other sources with whom Travelex work closely to provide the Travelex Services to you (including Travelex partners, third party payment and delivery service providers, advertising networks, analytics providers,
  • identity verification services, credit reference agencies, fraud prevention services and social media platforms).

To provide a requested service or fulfil our contract with you

• collecting payment, processing and fulfilling your order and otherwise providing you with the information and Travelex Services you request from us;
• providing you with any alerts, in-app messages or other messages, and newsletters that you have registered to receive;
• when we partner with other organisations to provide a particular Travelex Service (these partners will be identified to you at the time of the provision of the relevant Travelex Service e.g. when you visit the partner website or bureaux de change);
• providing you with service messages which tell you about changes to Travelex Services or to our terms, conditions and policies;
• enforcing any contract between you and us for the provision of Travelex Services.

Where we have your consent

• contacting you (including by email, social media or SMS) with marketing messages according to your preferences.
• contacting you via email with short surveys, according to your preferences;
• when you are using a mobile device (such as mobile phone, tablet or wearable device), we may use your precise geo-location to provide you with location-based services and provide you with targeted advertisements. You can control your geo-location settings within the app or your mobile device settings;
• enabling us and third-party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or any other relevant information;
• emailing you an e-receipt for your purchase if you choose to receive one;
• collecting your marketing preferences and sharing these with a Travelex Partner where you use our partner branded services.

Where we have a legitimate interest

• analysis and research to allow us to help make the Travelex Services personalised and relevant, as well as to develop our Travelex Services.
• sharing any loyalty card number you have provided to us, with the providers of the loyalty scheme, in order for you to receive points, where you have already consented to this with the loyalty scheme provider;
• Travelex carries out direct marketing from business to business (B2B) if you engage with us in your professional capacity (for example: if you represent a company with whom Travelex have an existing or prospective business relationship). We may keep B2B customers up to date with services we offer/provide, but you will have the right to opt out of receiving marketing communications at any time. To see how you can exercise your right to opt out, see the sections on 'How to opt out' below.

Note that where we rely on legitimate interests for processing your information, we carry out a 'balancing test' to ensure that our interests are not outweighed by your fundamental rights of privacy. More information on such balancing tests is available from Travelex on request.

Where we have a legal obligation

• to notify you about changes to Travelex Services and send you other administrative information;
• we may check the information you have provided to us to confirm your identity and to combat fraud. This is to comply with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening).

We use an external company, Trustpilot A/S (“Trustpilot”) to collect your feedback which means that we will share your name, email and reference number with Trustpilot for the purpose. By registering with Trustpilot, they will become the data controller of the personal information you have given them. You may edit your reviews and account information at any time on the Trustpilot site. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here.

• In the event that our business is acquired by a third party, or we enter into any kind of merger or other acquisition type, your information where required would be shared with the relevant party. We will notify you of this through the most appropriate means.
• We may also share your information with businesses that we partner with to offer Travelex Services under that partner's branding (e.g. featuring their logos and via their websites or bureaux de change). They may only market their own products or services to you if you consent that they can do so). Travelex may be the 'Data Controller' of the personal data you provide when using these services (which means we determine how personal data is used) or 'Data Processor' (which means we act on the written instructions of that partner on how to use personal data) of this data. The relationship will be indicated to you via the privacy policy available at the partner's website or partner-branded bureaux de change.
• Our partners include:
• Supermarket chains;
• Banks and building societies;
• Airports and airlines;
• Other retail businesses.
• We may share your Personal Information with fraud prevention agencies and tools. This includes checking the information you provide to us against information from ThetaRay and Experian. These agencies and tools keep a record of our enquiries and information we give them to help make decisions that to prevent fraud and money laundering.
• We may also disclose information about you to law enforcement authorities or other government officials, if we are required to do so by law or legal process, or when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity such as financial crime.
• We also share your information with a third party when we:
  • have your prior consent to do so e.g. where you your consent to receiving marketing from our partners, we will share that information with those partners;
  • are processing your information through a trusted service provider, who is acting on Travelex's explicit instructions and in accordance with this Privacy statement, confidentiality and levels of security in order to provide Travelex Services;
    
    Our trusted service providers include:
  • payment gateways and payment services providers
  • international money transfer services providers
  • identity verification providers and credit referencing agencies
  • providers of fraud prevention, anti-corruption and anti-money-laundering checks
  • cloud and online security services providers
  • outsourced service providers to the Travelex Group
  • providers of telecommunications, webchat and networking services
  • marketing communications providers
  • online advertisers and targeted advertising providers
  • social media networks

• Where we are using a third party to send targeted advertisements on our behalf, using an identifier such as an email address or site cookies. This will only be done with your express consent, in accordance with our Cookie Statement;
• Where we have aggregated, non-personally identifiable information, which is to be used for segmentation, statistical modelling, general research or trend analysis;
• If we sell or buy any new business or assets, in which case we disclose your information to the prospective seller or buyer of such business assets;
• If we are purchased by a third party, in which case information held by us including your information will be transferred.
• If we need to comply with the obligations we have to our third party product issuers or third parties providing products or services on our behalf, so that they can process your order or otherwise provide the information, products or services you have requested (please note that these third party product issuers have their own privacy policies and accordingly we cannot accept any responsibility or liability for the handling of your information by such third parties in accordance with such policies);
• If we need to enforce our Sites terms of use.

Our security measures:

• information you send us via our website, app or other Travelex systems are encrypted. This makes it unreadable to anyone who might try to listen in;
• updating and patching our servers in a timely manner;
• Our cyber control team proactively monitors for abnormal and malicious activity in our servers and services;
• When information you've given us is not in active use, it is encrypted at rest.

We are regularly audited to confirm we remain compliant with our security certifications, including SOC 2 and PCI-DSS. As part of these audits, our security is validated by external auditors.

We restrict access to your personal information to Travelex employees who have a business reason for knowing such information and third-party service providers' processing data on our behalf.

All Travelex employees who have access to your personal data are required to adhere to this control and all third-party service providers are requested by Travelex to ensure appropriate safeguards are in place. In addition, contracts are in place with third-party service providers that have access to your personal data, to ensure that the level of security and protective measures required is in place, and that your personal data is processed only as instructed by us.

We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, technical and organisational safeguards that comply with applicable laws and regulations to protect your personal information from unauthorised access.

• As a regulated financial institution, we have to retain information about your transactions because we have to keep detailed records for tax and accounting purposes or as required by anti-money laundering or anti-fraud regulations.
• When determining the relevant retention periods, we will take into account factors including:
  • our contractual obligations and rights in relation to the information involved;
  • legal obligation(s) under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law(s);
  • (potential) disputes;
  • guidelines issued by relevant data protection authorities; and
  • our legitimate interests, where we need to consider retaining information to meet any other obligations.

Otherwise, we securely erase your information once this is no longer needed.

How to opt out of Travelex marketing and surveys

We may use the information you give us on our Sites for direct marketing purposes to provide you with updates, newsletters, events, offers and promotions or other communications by email, that we think may interest you but, where required by law your prior consent will be obtained before sending direct marketing.

To continually improve Travelex products and services, Travelex or a third-party partner of Travelex may send you emails containing requests for feedback and/or reviews.

For example, if you purchase a particular currency, we may use this information to inform you of travel information, new product updates, or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we use pseudonymised data wherever possible.

This activity has no legal effect on you.

We use automated processes to check that your application to access and use Travelex services meet our regulatory requirements, including verifying your identity, and to help prevent fraud or other illegal activities. These processes may make an automated decision to reject your proposed transaction, to block a suspicious attempt to login to the Travelex App. If this happens, you will be notified and offered the opportunity to provide further information and challenge the decision through an appeal mechanism, which includes a manual review. In any case, if you feel that an automated process may have impacted you, please contact Travelex Customer Support under the 'Contact' section below.

If you access other sites using the links provided, the operators of these sites collect information from you which will be used by them in accordance with their privacy statement and accordingly we cannot accept any responsibility or liability for such policies.

On some pages of our Sites, third parties that provide content, applications, services (such as a webchat service enabling you to speak to an adviser about the Travelex Services) or plug-ins through our Sites track your use of content and our applications or customise content, applications and plug-ins. For example, when you share an article using a social media button on our Sites (e.g. Facebook, Twitter, LinkedIn, or Google Plus), the social network that has created the button will record that you have done this, or when you speak to an advisor about the Travelex Services, they may provide you with advice over our chat facility. You should check the Privacy statement of third-party websites to find out how they manage cookies and process your information.

In all cases where we transfer information across borders, we rely on defined legal mechanisms to ensure that we protect data at all times. For transfers between Travelex group companies, we have in place an intra group transfer agreement. Or we may use new standards as these are developed by the appropriate regulatory authorities.

• The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing.
• The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this Privacy statement.
• The right of access. You have the right to obtain access to your information (if we're processing it), and certain other information (similar to that provided in this Privacy statement). This is so you're aware and can check that we're using your information in accordance with data protection law.
• The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by writing to us using the contact details below.
• The right to erasure. This is also known as 'the right to be forgotten' and, in simple terms, enables you to request the deletion or removal of your information that we hold by writing to us using the contact details below.
• The right to restrict processing. You have rights to 'block' or supress further use of your information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be 'blocked' to make sure the restriction is respected in the future.
• The right to data portability. You have the right to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.
• The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator.
• The right to withdraw consent. If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your information at any time.

Any changes we make to our statement will be posted on our Website. We will advise you of significant changes to this statement where we have your contact details.

Questions, comments and requests regarding this Privacy statement are welcomed and should be addressed to customerservices@travelex.com or Customer Services Department, Worldwide House, Thorpe Wood, Peterborough PE3 6SB.

Our Data Protection Officer can be contacted at dataprotectionteam@travelex.com.