Travelex Privacy Statement
Your privacy and your rights are important to us. This privacy notice explains what information we collect about you and how we use it. By ‘we’ or ‘us’ or ‘our’ we mean Travelex Currency Exchange Limited, Room 302, 3/F, North Office Block, Super Terminal 1, Hong Kong International Airport, Hong Kong.
If you subscribe to, or have purchased, Travelex products and services (instore or online), you visit our websites or you download and use our mobile apps,
- Travelex recognises the importance of safeguarding the personal information (“information”) of its customers using the Travelex Services. This Privacy Notice (the “Notice”) 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 Limited 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”),
- you obtain services from our bureaux de change stores, by either using our online Click and Collect service 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, live chat, SMS, or social media platforms;
- you purchase or use Travelex branded products or services “Travelex Services”.
2. What information we collect
Travelex collects, stores, processes, and discloses (collectively "uses") your information in a manner consistent with the Data Protection Principles (DPP’s), established under the Hong Kong Personal Data (Privacy) Ordinance (PDPO) (Cap 486).
We collect and process your information in the following ways:
Information you give us
- You give us information about yourself when you purchase or use Travelex Services, or communicate with us (whether in writing, by phone, via social media or by any other means), or enter into any of our competitions, promotions or surveys. Where we request information from you, we will collect your information in the relevant forms or pages we use, including when you set up an account with us or when you register for loyalty schemes offered by us. You can choose to provide additional information to us when you contact us or otherwise interact with us.
- If you subscribe to receive our newsletter, then you will provide us with your name, email address and information indicating how you heard about us. You can also provide us with information on your marketing preferences.
- If you purchase any Travelex Services, we will collect information from you that will enable us to complete your transaction. Such information can include your name, date of birth, home address, billing address, office address, e-mail address, the form(s) of identification you provide (e.g. passport or driving licence) and the information contained within those forms of identification, mobile telephone number, landline telephone number, credit or debit card information, other payment details, such as your bank account information, as required by us in order to complete your transaction and provide your payment choices and travel details (including future travel dates and destinations). If you do not provide the information we require to process a transaction, we may not proceed with your order.
Information we collect automatically
- Travelex also collects certain information about you by automated means, such as cookies, whenever you visit our Sites or when you use the Travelex Services and how you use them.
- When you access our services from a mobile device we may collect personal information from you such as, your name, email address, user name, 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 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 ensure that content from our Sites is presented in the most effective manner for you and your devices; and
- as part of our effort to keep our Sites safe and secure;
- When we collect CCTV images of you when you visit our premises such as at our bureaux de change stores, we will do so for the prevention and detection of crime and public safety.
Information we receive from third parties
- We may also receive 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, identity verification services, credit reference agencies, fraud prevention services and social media platforms).
3. How we use the information we collect
The information we hold on you will be used 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 use 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, or you have given your consent to receiving this information.
We use your information for the following purposes:
To provide a requested service or carry out a 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 service messages, including messages notifying you about changes to Travelex Services or changes to our terms, conditions and policies;
- enforcing any contract entered into 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 marketing
- contacting you via email with short surveys, according to your survey preferences;
- where you have consented, collecting your marketing preferences
Where we have a legitimate interest
- data analysis and research to allow us to derive insight and to help make the Travelex Services personalised and relevant, as well as to develop our business processes and Travelex Services. In doing so, we will anonymise your data so that we may continue to use it for analysis and research after the period that it has been used for processing our services to you. Where data is anonymised, we ensure that it cannot be used (singularly or with other data) to re-identify you;
- 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) which means, 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 you up to date with services we offer/provide. B2B customers 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 section 5 below.
Where we have a legal obligation
- complying with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This includes checking the information you provide to us against information from Thomson Reuters.
4. Information we share
We only share your information with Travelex Group Companies and with other companies in the limited circumstances set out below, for specific purposes. We do not 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 be shared with the relevant party.
- 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). Our partners include:
- Payment platforms;
- Banks and local money service businesses;
- Airports and airlines;
- Travel agents;
- Other businesses.
- We share your Personal Information 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: 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;
Our business partners 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
- social media networks
- 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;
5. How to opt in or opt out from direct marketing, third party marketing and surveys
We may use the information you give us on our Sites for direct marketing purposes to but, where required by law your prior consent will be obtained before sending direct marketing.
We may also from time to time send you surveys about or products and services. We will only do this where we have your consent.
You have the right to opt in or opt out of direct marketing and surveys from us at any time by clicking on the unsubscribe link in any email we send to you.
6. Third Party Marketing Cookies and Social Advertising
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 statements and opt out options.
7. Retention of your Information
We will keep 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, to be able meet our legal and contractual obligations to you, and if necessary, to resolve any disputes. We will not keep more information than we need. 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
- 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.
8. Links to Third Party and Travelex Group websites
Our Sites may 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 Notice.
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 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.
We take all reasonable steps to ensure that all information collected through our Sites is treated securely and in accordance with this Notice. We do this by applying appropriate technical and organisational measures that meet all of the standards of our regulatory obligations, including regular review measures.
We have a number of security measures in place to protect your information you provide to us through our Sites 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.
10. International Transfers
In providing the Travelex Services to you we sometimes transfer your information to other countries. Where we transfer your information outside Hong Kong. in this way, we ensure that all data is treated with the same security measures regardless of location, and in accordance with our standards, policies, regulatory and legal obligations.
The internet is a global environment, so using the internet to collect and process your information necessarily involves transmitting data internationally. Therefore, by browsing our Sites 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 Sites is treated securely and in accordance with this Notice and strict data protection standards.
11. Your rights
By law, you have a number of rights (subject to certain conditions) when it comes to your information.
- 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 Notice.
- 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 Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law. You can do this by writing to us using the contact details in Section 13.
- 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 in Section 13.
- 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 by contacting us using the contact details in Section 13.
12. Changes to Our Notice
This notice was last updated on the 31 May 2021. It will be updated from time to time to take into account changes to the Travelex Services or, for example, to reflect changes to applicable regulations.
Any changes we make to our notice will be posted on our Website. Please do check our 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 bureaux 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.
Our Data Protection Officer can be contacted at:
The Data Protection Officer,
Travelex Currency Exchange Limited.
Room RB302, 3/F, North Office Block, Super Terminal 1,
Hong Kong International Airport,
Travelex Customer Service Hong Kong: firstname.lastname@example.org
14. English and Chinese versions of Travelex Privacy Statement
If there is any inconsistency between the English and Chinese versions of Travelex Privacy Statement, the English version shall prevail.