Travelex Privacy Notice
We
have updated our Privacy Notice, in line with Law No. 30 of 2018 with respect to Personal Data Protection (Data
Protection Law), enacted July 12 2018 and in force August 1 2019
Our bureaux de change, this
website: www.travelex.bh (the "Website") and our customer services telephone line are operated by Travelex
Bahrain WLL (“Travelex” or "us" or "our") on behalf of itself and its holding companies and
subsidiaries (together, the "Travelex group"), recognises the importance of safeguarding the personal
information of its customers. The following Privacy Policy sets out the basis on which any personal information
will be processed by us and reflects Travelex's commitment to maintain the confidentiality of personal
information and to provide its customers with the best possible service.
When is Personal Information
Collected?
You may be asked by staff at one
of our Travelex bureaux, prompted at various points on our Website or asked by one of our customer services
telephone advisers to provide us with your personal information.
What Personal Information
do we Collect?
Accordingly, we may collect and process the
following information about you:
- information you provide by filling in forms
at one of our bureaux;
- details of any transactions you carry out
in-store at one of our bureaux and of the fulfilment of your order(s);
- information you provide when entering
Travelex prize draws or competitions;
- information collected from optional
surveys;
- information you give us
when you call the customer services telephone line or when you interact with us using other channels
including by email, SMS or social media platforms;
- details of your visits to the Website and the
resources that you access
- cookies and web beacons, whenever you visit
our Websites; and
- if you contact us, we may keep a record of
that correspondence
- we may collect CCTV images
of you from equipment in place when you visit our bureaux de change stores, but we will only do so for the
prevention and detection of crime and public safety.
How we Use the Information we
Collect
We will only collect, store,
use, share retain or delete (“process”) your personal information for the purposes identified
below.
Where we have your
consent:
- sending you an e-receipt, if you confirm you would like one;
- contacting you (including by email, social
media or SMS) with marketing messages according to your marketing preferences.
- sending you SMS messages
about the status your transactions, if you have requested this
- contacting you via email with short surveys,
according to your survey preference
- enabling us and third
party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or
any other relevant information unless you have indicated you would not like us too;
To implement a contract
with you, or to take any steps that you tell us to, in order to complete our contract with
you:
- collecting payment,
processing and fulfilling your order and otherwise providing you with the information and 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.
To implement an obligation required by
law or an order from a court:
complying with our legal and
regulatory obligations (including fraud prevention, anti-money laundering and sanction
screening).
To exercise our legitimate interests,
unless this conflicts with your fundamental rights and freedoms:
- improving customer
experience and our quality of Travelex services. This can also include tracking emails to know when they
are opened and read and the type of device they emails are accessed from; 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 (on its own
or with other data) to re-identify you.
Retention of Personal
Information
We will keep your information
only for as long as is necessary for the purposes set out in this Privacy Notice. 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 or for anti-money laundering or anti-fraud
obligations.
Maintenance of
Accurate Information
We strive to ensure that the
information we maintain about our customers is accurate, current and complete. We respond to requests from
customers to correct inaccurate information in a timely manner.
Protection
of Information via Established Security Procedures
We will apply appropriate
technical and organizational measures capable of protecting the personal information you provide to us
against unintentional or unauthorised destruction, accidental loss, unauthorized alteration, disclosure or
access, or any other form of unauthorised or unlawful processing.
For example, when you place
an order for reserving currency online with us, your order is placed over a secure connection and your
personal information is encrypted to ensure it remains safe at all times.
Once we receive your personal
information, we use strict security standards and procedures to help prevent unauthorised access. Where
Travelex is required to make paper copies of your personal information, such information is either:
- stored in a secure locked storage
facility and when required, archived in the same manner; or
- scanned onto our secure
electronic systems (with the original paper copies shredded and destroyed) and, when required, archived
in a safe and secure manner.
All personal information
which is provided online is stored on our secure electronic systems and archived in a secure manner.
We will take reasonable steps
to ensure any third parties who process your personal information on our behalf, provide sufficient
guarantees to us about applying similar technical and organisational measures.
Disclosure of
Personal Information to Third Parties
We may disclose your personal
information to any member of the Travelex group (which means our subsidiaries, our ultimate holding company
and its subsidiaries). We will not share personal information with third parties outside of the Travelex
group for marketing purposes without your consent.
We may disclose your personal information to
third parties for the following purposes:
- in the event that we
sell or buy any business or assets, in which case we may disclose your personal information to the
prospective seller or buyer of such business assets;
- if Travelex or
substantially all of its assets or Travelex’s holding company or substantially all of its assets
are acquired by a third party, in which case personal information held by us about our customers will be
one of the transferred assets; and
- in accordance with the
obligations bestowed on us by our third party product issuers so that they may process your order and,
unless you have indicated that you would not like us to do so, keep you informed of similar products or
services to those which you have bought (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 personal information by such third parties in accordance with such policies);
- if we are under a duty
to disclose or share your personal information in order to comply with our legal obligations or in order
to enforce our conditions of sale (including the Online Terms and Conditions) and other agreements; or
to protect the rights, property, or safety of Travelex, our customers, or others. This includes
exchanging information with other companies and organisations for the purposes of fraud protection and
credit risk reduction.
Transfers of Personal
Information to other Countries
The personal information that
we collect from you may be transferred to, and stored at, a destination outside the Kingdom of Bahrain. It
may also be processed by staff operating outside the Kingdom of Bahrain who work for us or for one of our
suppliers (including third party product issuers). Such staff may be engaged in, among other things, the
fulfilment of your order, the processing of your payment details and the provision of support services. By
submitting your personal information, you agree to this transfer, storing or processing.
We will only transfer data to such
countries
- where the standards of
data protection that are deemed equivalent to the Data Protection Law by the Data Protection Authority,
or
- we need to send personal information to a
fulfilling the contract
We will always ask for and
obtain your consent to send your personal information to any country that does not fall within the above two
categories
IP Addresses and
Cookies
We may collect information
about your visits to the Website and your computer (including where available, your IP address, operating
system and browser type) for system administration and to report such information to our advertisers. This
is statistical data about our users' browsing actions and patterns, and does not identify you as an
individual.
We collect such information
by using a "cookie" file. Cookies are small pieces of information that are stored on your computer's hard
drive by your browser. They help us improve the Website and make it possible for Travelex to identify some
of your preferences. On revisiting the Website, Travelex's computer server will recognise the cookie, giving
us information about your previous visits.
Most browsers are originally
configured to accept cookies automatically, however, you may refuse to accept cookies by activating the
setting on your browser which allows you to refuse the setting of cookies. Please note that if your browser
is not configured properly or if you alter your browser to disable the acceptance of cookies,
you may not be able to use
the Website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will
automatically issue cookies when you log on to the Website.
Please note that our advertisers may also use
cookies, over which we have no control.
Right to Object to
Processing
You have the right to object
to how Travelex processes your personal data. If you have any questions or concerns about how we use your
data please email onlineadminbahrain@travelex.com.
Links to Third Party
Websites
Our site may, from time to
time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you
follow a link to any of these websites, please note that these websites have their own privacy policies and
accordingly we cannot accept any responsibility or liability for such policies. It is therefore advisable to
check these policies before you submit any personal information to these websites.
Changes to Our
Privacy Policy
Any changes we make to our
Privacy Policy in the future will be posted on this page. Please do check our Privacy Policy from time to
time to take notice of any changes made. By providing us with your personal information, using the Website
and/or any service offered via the Website, in-store at one of our bureaux or over the phone, or by placing
orders after we have changed the terms of our Privacy Policy, you will be deemed to have accepted these
changes.
This Privacy Policy was last updated on 15
July 2019.
Removal from Travelex
Email Marketing Communications
You may want to discontinue
receiving information from the Travelex group. While this may mean that you will not receive product or
service information of interest to you, we respect anyone’s wishes not to be informed directly of these promotions
or product introductions by emailing onlineadminbahrain@travelex.com. Please specify that you want
to be removed from the Travelex email database. You will also be provided with an unsubscribe link in any
email marketing communications we send you.
Contact
Questions, comments and
requests regarding this Privacy Policy are welcomed and should be addressed to onlineadminbahrain@travelex.com.
Travelex
Bahrain WLL,
Landside Departures, Bahrain International Airport, Muharraq,
Kingdom of Bahrain.