Travelex Privacy Notice
- If you subscribe to or have purchased Travelex products and services, this Privacy Notice forms a part of your contract with Travelex.
- Travelex recognises the importance of safeguarding the personal information (“information”) of its customers using the Travelex Services. This Privacy Notice (the “Policy”) sets out the basis on which any of your information will be collected, stored and used by us, and reflects Travelex's commitment to maintain the confidentiality and security of your information, and to provide its customers with the best possible service.
- This Website is provided by Travelex NV and describes how your information is used by a member of the Travelex Group Companies (“Travelex”, “we”, “us”, “our”) when:
- you use this website (the “Website”), any of our mobile software applications (Apps) or platforms (together the “Sites”);
- you obtain services from our stores, by either using our online channel or by walking in to one of our stores;
- you call the customer services telephone lines or when you interact with us using other channels including by email or social media platforms;
- you purchase or use Travelex branded products or products we provide under the branding of our partners. These services and products are collectively referred to in this Policy as “Travelex Services”. Our partners include:
- Airports and airlines;
- Other retail businesses.
- Travelex processes your information in a manner consistent with the General Data Protection Regulation 2016/679 (GDPR) that governs the EU, as well as the local laws of the countries in which it does business. For The Netherlands, The Algemene Verordening Gegevensbecsherming (‘AVG’) is van toepassing.
- If you have any requests concerning your information please refer to Section 11, or if you have any queries with regard to our practices please contact us using the contact details in Section 14.
- What Information we process
We process your information when you interact with us for the provision of Travelex Services or through interaction with our websites or promotions. The information we process is either information you give to us, information we collect automatically, information we receive from third parties or information you provide about other people.
We collect and process your information in the following ways:
Information you give us
Information we collect automatically
Information we receive from third parties
- Non-personal information used to supplement existing information, such as demographics and affluence metrics.
- Information about you from other members of the Travelex Group Companies, and 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).
- Why we process the information we collect
The information we hold on you will be processed in a number of ways. This is generally to provide you with the services that you request from us, to keep you informed and to improve your customer experience and the quality of the Travelex Services. In some instances we process this information to send you marketing communications we think are relevant to you, but we only do this where it is lawful to do so and you have given your consent to receiving this information. You have the right to object to us sending you such information, at any time.
To provide a requested service or carry out a contract with you
Where we have your consent
Where we have a legitimate interest
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
- Information we share
Even where shared, we ensure your information will only be used for the purposes outlined in this policy.
We share your information with Travelex Group Companies, companies that we deliver services for under that partner’s logo and branding, with third party product issuers, companies that provide services or communications to you on our behalf and where we are subject to (or reasonably believe that there is) a requirement to share such information to comply with our legal obligations.
Except, as above, we do not share your information with companies, organisations or individuals outside of Travelex for marketing purposes nor do we sell your information.
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/can be shared with the relevant party.
- We share your Personal Data with fraud prevention agencies in the provision of certain Travelex Services to you. These agencies keep a record of our enquiries and record, use and give out information we give them to make assessments and to help make decisions on you to prevent fraud and money laundering.
- We 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;
- are processing your information through a trusted business partner, who is acting on Travelex's explicit instructions and in accordance with this Notice, confidentiality and levels of security;
- are using a third party to send targeted advertisements on our behalf, using an identifier such as an email address or site cookies;
- have aggregated, non-personally identifiable information, which is to be used for segmentation, statistical modelling, general research or trend analysis;
- 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;
- are purchased by a third party, in which case information held by us including your information will be transferred. We will notify you of this through the most appropriate means;
- 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);
- How to opt in or opt out from direct marketing, third party marketing and surveys
We use the information you give us on our websites for direct marketing purposes to provide updates, newsletters, events, 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 unsubscribe you can click the 'unsubscribe' link in any email we have sent you, by calling us, or you can also visit our Privacy Centre to manage your preferences.
- Third Party Marketing Cookies and Social Advertising
- You can choose to ‘decline’ the Third Party Cookies that enable this type of marketing at any time by visiting our cookie preference centre
- We encourage you to learn more about how companies use advertising on social media and how to adjust your marketing preferences by checking their privacy statement and opt out options.
- Retention of your Information
We will process your information only for as long as is for the purposes set out in this privacy notice and to fulfil our legal obligations. Where you are a customer this is usually at least for as long as you remain a customer and a period after this to be able meet our legal and contractual obligations to you, and if necessary, to resolve any disputes. We will not process more information than we need.
- We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we retain some of your information after you cease to use Travelex Services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes or for Anti Money Laundering obligations.
- 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 (for example, our obligations under anti money laundering laws);
- 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.
- Links to Third Party and Travelex Group websites
Our websites contain links to and from the websites of our group companies, selected partner networks, advertisers and affiliates, including websites which are outside of our control and are not covered by this Privacy Notice.
- If you access other websites using the links provided, the operators of these sites collect information from you which will be used by them in accordance with their Privacy Notice, which differ from ours. Please note that these other sites have their own privacy policies and accordingly we cannot accept any responsibility or liability for such policies.
- On some pages of our websites, 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, applications and plug-ins or customize content, applications and plug-ins for you. 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 will provide you with advice over the Facebook chat facility, Facebook has access to your information. You should check the privacy notice of third party websites to find out how they manage cookies and process your information.
We take all reasonable steps to ensure that all Personal Data collected through our websites is treated securely and in accordance with this Privacy Notice. We do this by applying appropriate technical and organisational measures, that meet all of the standards of our regulatory obligations, including periodic review measures .
- We have a number of security measures in place to protect your Personal Data you provide to us through our websites against unauthorized disclosure, use, alteration, or destruction. However, when transmitting information over the internet, please bear in mind that no transmission over the internet can ever be guaranteed secure. Therefore, while we endeavour to protect your information, please note that we cannot guarantee the security of any information that you transfer over the internet to us.
- As part of using our websites, you are sometimes asked to set-up a user name and password. You are responsible for maintaining the confidentiality of your user name and password and are responsible for all activities that are carried out when logged using your name and password. You are responsible for ensuring the security of the passwords that you set.
- International Transfers
In providing the Travelex Services to you we sometimes transfer your information to other countries. Where we transfer your information outside the European Economic Union or EEA (i.e. countries that are members of the EU together with Norway, Iceland and Lichtenstein) we ensure that all data is processed with the same standards of security measures regardless of location, in accordance with our standards, policies, regulatory and legal obligations.
- Given that the Internet is a global environment, using the Internet to collect and process your Personal Data necessarily involves the transmission of data on an international basis. Therefore, by browsing our websites and communicating electronically with us, you acknowledge our processing of your information in this way. However, we will take all reasonable steps to ensure that all information collected through our websites is treated securely and in accordance with this Notice and strict data protection standards.
- In providing our services to you, such as fulfilling orders and taking payments, we transfer the Personal Data we collect from you and about you to destinations outside of the European Economic area (“EEA”). This is because the information is processed in other locations. Where we do so, we ensure that security measures and appropriate safeguards are put in place to protect your information and ensure that all transfers of your information comply with applicable data protection law. We also ensure that processing is only ever carried out in accordance with our instructions.
In all cases where we transfer information across borders, we rely on defined legal principles to ensure that we protect data. These principles are model contractual clauses that have been provided by the EU, adequate protections that have been defined by the European Commission, and for transfers between Travelex group companies, we have in place an intra group transfer agreement. If new standards of contract emerge and are approved by a supervisory authority in the future, we will seek to reinforce our procedures accordingly.
- Your rights
Based on the AVG, you have a number of rights (subject to certain conditions) when it comes to your Personal Data. These include the right to ask us what information we process, and to request us to modify any incorrect details, add missing information, or to delete the Personal Data we process. You also have the right to object to us processing your data or ask us to restrict processing your Personal Data. If you want to process the information that we hold about you for services with others, you can ask us to provide your Personal data in a commonly used electronic format. You can exercise any of these rights by contacting us using the contact details and form referred to in Section 14.
You can obtain further information about your rights, or make a complaint to the Autoriteit Persoonsgegevens (‘AP’) with regards to how we use your information, and Section 14 provides contact details should you need them.
- The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other Travelex services which we think will be of interest to you or being contacted with varying potential opportunities).
- The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we process your information and your rights. This is why we’re providing you with the information in this Notice.
- The right of access. You have the right to obtain access to your Personal Data (if we’re processing it), and certain other information (similar to that provided in this Privacy notice). This is so you’re aware and can check that we’re processing your Personal Data in accordance with the AVG. You can do this by writing to us using the contact details in Section 14
- The right to rectification. You are entitled to have your Personal Data corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we process by writing to us using the contact details in Section 14.
- The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the full or partial deletion or removal of your Personal Data that we process by writing to us using the contact details in Section 14.
- The right to restrict processing. You have rights to ‘block’ or supress further processing of your Personal Data. 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 rights 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 process your information with the Autoriteit Persoonsgegevens.
- The right to withdraw consent. If you have given your consent to all processing of your Personal Data), 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 by contacting us using the contact details in Section 14.
- Privacy of minors
In a very limited number of instances, we process information on minors under the age of 16 when they use specific Travelex Services, but only with the consent of a responsible guardian or parent.
- We process Personal Data on minors under the age of 16 for the purpose of providing foreign currency or performing Mr. pay transactions. This only applies where an accompanied minor walks in to one of our stores and carries out a transaction over-the-counter. We only collect this information with the prior consent of the responsible parent or guardian that accompanies them.
- We do not knowingly collect or solicit any additional information from minors under the age of 16. If you are under the age of 16, you should not register or provide information on the Travelex Applications. If we later obtain actual knowledge that a user is under 16 years of age, we will take steps to remove that user’s information from our systems where section 11 does not apply. If you believe that we might have any information from or about a minor under 16, please notify us using the contact form at section 14.
- Changes to Our Privacy Notice
This notice was last updated on the 23rd of May 2018. It will be updated to take into account changes to the Travelex Services or for example to reflect changes to applicable regulations.
Any changes we make to our Privacy Notice will be posted on our Website. Please do check our Privacy Notice to take notice of any changes made. By providing us with your information, using the online services and/or any service or product offered via the online services, providing us with information in-store at one of our stores or over the phone or by placing orders after we have changed the terms of our Notice, you will be deemed to have accepted these changes. We will advise you of significant changes to this Notice where we have your contact details.
- Questions, comments and requests regarding this Policy are welcomed and should be addressed to firstname.lastname@example.org or Travelex NV, Postbus 721, 1000 AS Amsterdam o.v.v. Dataverzoek
- Our Data Protection Officer can be contacted at email@example.com
- The Dutch Regulator for Personal Data regulation is the Autoriteit Persoonsgegevens (‘AP’).
The AP can be reached:
De Autoriteit Persoonsgegevens
PO BOX 93374
2509 AJ DEN HAAG
or during the telephone consultation (Monday through Friday from 0900 uur to 1700 uur) through phone number: 088-1805250 (10ct per minute)