EFFECTIVE DATE: February 25, 2013
Travelex Currency Services Inc (“Travelex” or "us" or "our"), on behalf of itself and its holding companies and subsidiaries (together, the "Travelex Group"), provides the following details about our privacy practices regarding information collected, used and shared by us at www.travelex.com ("Website"), our Mobile App, and other Travelex interactive and mobile applications (collectively, "Travelex Applications").
2. Why We Ask You For Your Personal Information
We ask you for your personal information for the following purposes:
- to facilitate the provision of the products and services you request from us including verification of your identity;
- to provide you with information and offers on our products and services, that we believe may be of interest to you, and in certain circumstances to allow Travelex group companies (that is, Travelex subsidiaries and affiliates) to provide you with information about their own products or services; and
- to comply with the law; and
3. Information We Collect
Information We Collect From You
Information We Collect About You: If you choose to order products or services from us, via telephone, mail, in person at one of our retail stores, from our Website, or our Mobile App you will have to provide us with certain information, including personal information such as: your name, mailing and/or e-mail address, credit or debit card information, Driver’s License or passport and/or other photographic identification. We may also obtain information about your transactions with us and/or the Travelex Group and other information for payment purposes or to comply with legal requirements.
Federal law requires us to obtain, verify and record information in order to confirm your identity. This information will include your name, address, date of birth and any other information required in order to complete the verification process. The information provided by you and the results of the verification process will be retained by Travelex and our third party fraud checking agent for audit and fraud prevention purposes.
Information We Collect and How We Use It
Supplemental Information: We may from time to time supplement information you give us with information from other sources, such as information to validate or update your address. We use this information to help us maintain the accuracy of the information we collect and for internal business analysis or other business purposes.
Information Collected Through Technology
In addition to any personal information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Travelex Applications ("Usage Information"). This may include the browser that you are using, the URL that referred you to the Travelex Applications, all of the areas within the Travelex Applications that you visit, location, and the time of day, among other information. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the Travelex Applications. In addition, we collect your IP address or other unique device identifier (“Device Identifier”) for your computer or other device used to access the Travelex Applications (any, a “Device”) and may identify your specific location for certain services available on our Mobile App, as more clearly spelled out in this policy ("Geo-location"). A Device Identifier is a number that is automatically assigned to the Device used to access the Travelex Applications. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your personal information, we will treat it as personal information.
A few of the tracking technologies that may be used to collect Usage Information include, without limitation, the following:
- Web Beacons: We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our Website and messages by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages.
- HTML5: We use HTML5 in the Travelex Applications for the iPhone or iPad (and other Apple iOS devices). HTML5 has browser web storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies are not stored in a browser “cookies” file and, like Flash cookies, can be used to track users across Travelex Applications. HTML5 is only used by us to complete the transaction process and is then deleted by us. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage from that device.
- Web Logs: Like most standard website servers, we log Device Identifiers in order to improve security, analyze trends and administer the Travelex Applications. We may track your movement within the Travelex Applications, the pages from which you were referred, access times and browser types. This information may also include the browser you are using, the Internet address from which you linked to our Travelex Applications, and the operating system of your computer. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Travelex Applications, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information.
- Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Travelex Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Travelex Applications, and is deactivated or deleted thereafter.
- Geolocation Services: When you have the Geo-location software running on your mobile phone, computer or other device, we may collect that information as controlled by your privacy settings on those Devices in order to assist you in searching Travelex locations where you can purchase our good and services. We only retain your location information to facilitate your search and do not share your Geo-location for any other purpose.
Third Party Analytics Technologies
Our Business Relationship
When you provide us with information in connection with a particular activity or purchase or provide your contact information, including an email address or telephone number in connection with that activity, product or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you future information about Travelex using the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Use Of Your Personal Information
If you provide information when buying travel money or other goods or services from Travelex, we may use such personal information for the purposes of:
- collecting payment and processing your order;
- complying with our legal and regulatory obligations (including fraud prevention and anti-money laundering);
- complying with our obligations to third party product issuers in accordance with the terms and conditions of their services;
- keeping you informed by email of similar Travelex Group products or services to those which you have bought, unless you have indicated that you would not like us to do so;
- providing you with any email of mobile alerts you have registered for; and
- ensuring that content from the Travelex Applications is presented in the most effective manner for you and for the device you use to access the services offered on the Travelex Applications.
Transactional Communications: We may use your personal information to contact you about services on our Travelex Applications for which you have expressed an interest, for example, if you have contacted customer service or made an inquiry. We may also send you announcements and emails from time to time relating to your account. You may not opt-out of these communications, which are not promotional in nature.
Offers And Promotional Messages via email or text: We may also use your email address (or mobile phone number if you have provided express consent to do so) to send you updates and communications about our products and services or other messages, such as alerts, text messages, or special offers. If you do not want to receive such messages, you may opt out or change your preferences by contacting us at the e-mail address or telephone number provided in paragraph 12 below. You also will be given the opportunity, in any promotional email or text message that we send to you to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. Follow the unsubscribe instructions included in each email or click "STOP" on a mobile text. You may also Contact Us or write us an e-mail to email@example.com.
Feedback: All comments, feedback or materials submitted by you to Travelex including feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis. Travelex will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, marketing and selling products and services incorporating such Feedback. You agree that in submitting Feedback, it will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will be or contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”. If you wish to access any personal information which may be associated with this information you can contact us at firstname.lastname@example.org.
Service Providers: We use third party service providers to help us operate our business and the Travelex Applications and administer activities on our behalf. We may share your information with these third parties for those limited purposes.
Strategic Partners: From time to time we may enter into a special relationship with another company that is not a Travelex Affiliate to provide additional features on the Travelex Applications. Since these third parties will use your information in accordance with their own privacy practices, you should check their websites for information regarding their privacy policies. These special relationships may include business partners, sponsors and co-branded Travelex Applications (referred to here as "co-branded pages"). Any information, including personally identifiable information that you provide on one of these co-branded pages will be shared with these third party partners. By participating in activities or providing your information on these co-branded pages, you also consent to our providing your personal information to those third parties.
4. Disclosure of and Control Over Personal Information
We will only disclose personal information to other Travelex group companies or third parties for everyday business purposes, such as to process your transactions, maintain your account(s), perform information technology functions, respond to court orders and legal investigations, report to credit bureaus, or to offer our products and services to you. Please note that these disclosures are not subject to an opt out choice, as such disclosures are necessary to run our everyday business.
5. Protection of Personal Information
The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Unfortunately, the transmission of information via the internet or mobile app is not completely secure and we cannot guarantee the security of information you transmit to us, and your use of the Travelex Applications indicates that you are willing to assume this risk.
6. Accessing Your Personal Information
There may be instances where we will not be able to provide the personal information we hold about you that you request. Some of these instances include if it:
- contains references to other persons;
- is subject to attorney-client or litigation privilege;
- contains our own proprietary information that is confidential to us;
- is too costly, in our determination, to retrieve; or
- cannot be disclosed for legal reasons.
If we are unable to provide you with access to your personal information, we will always explain the reason why, if possible.
7. Keeping Your Personal Information Accurate
8. Links to Third Party Websites
Our Site includes links to other websites whose privacy practices may differ from those of Travelex. If you submit personal information to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
9. Important Disclosures, Practices
Children's Privacy: Travelex does not knowingly collect or solicit personal information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide personal information on the Travelex Applications. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user’s personal information from our systems. If you believe that we might have any information from or about a child under 13, please contact us at email@example.com.
California Do Not Track Discolosure: Travelex's websites do not respond to Do Not Track signals.
11. Please Contact Us
Travelex Currency Service Inc.
29 Broadway, 1st Floor
New York, NY 10006
This is a list of third parties who provide us with information, reports and analysis about the usage and browsing patters of our users through tracking technology:
Google - http://www.google.com/intl/en/policies/privacy/
Flurry - http://www.flurry.com/about-us/legal/privacy.html
Optimizely - https://www.optimizely.com/privacy
Formisimo - http://www.formisimo.com/privacy-policy
© 2014 Travelex Currency Service Inc. All Rights Reserved.