Travelex Insurance Privacy Policy
Effective Date: December 12, 2023
- What Information Do We Collect?
- How Do We Use Your Information?
- Who Do We Share Information With?
- Protection of Information
- Links to Third Party Sites
- Notice to International Users
- Children’s Privacy
- Disputes
- Consumer Privacy Rights
- Nevada Resident Privacy Rights
- Your Choices
- Your Rights
- Changes to Privacy Policy
- Contact Us
- Accessibility
1. What Information Do We Collect?
Information You Provide Directly to Us
We collect information you provide directly to us in order to provide the best service possible. For example, we collect information when you: interact with Travelex Insurance in person, by phone, through mail or email, or through any website chat feature; request or purchase a plan; register for an account; participate in any interactive features of the Sites; subscribe to a newsletter or email list; participate in a survey, contest, promotion or event; request customer support; or otherwise communicate with us.
- Account Information. When you register or contract for an account on the Sites or other channels to become a partner, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include identifiers such as your name, email address, mailing address, username, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience. We may combine this information with the personal information we collect from you.
- Transaction Information. If you choose to order products or services from us 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 and/or other photographic identification.
- Content You Submit. We collect the content you submit to the Sites. This includes all comments, feedback or materials submitted by you to us, for example, feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (“Feedback”). Travelex Insurance will be free to use, display, perform, distribute, copy, adapt, and promote, without compensation to you, the Feedback for any purpose whatsoever.
- Verification Information. We may collect information to verify and confirm your identity. This information may include your name, address, date of birth and any other information required by us to complete the verification process.
- Surveys and Promotions. We may request information from you via surveys or promotions. Participation in these surveys or promotions, which might include contests or sweepstakes, is voluntary. Examples of requested information may include contact and demographic information.
1(a). Information We Collect Automatically
We and our third-party service providers or affiliates may use a variety of online tracking technologies, such as cookies, embedded scripts and web beacons, that automatically (or passively) collect certain information whenever you visit or interact with our Sites.- Usage Information. We collect information about your usage of, and interaction with the Sites. For example, we may track the number of people who view each page and all of the areas within our Sites you visit. We may also collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis.
- Location Information. With your permission, we may also collect information about the precise geolocation location of your device using methods that may include GPS, wireless networks, cell towers, and Wi-Fi access points. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see "Your Choices" below.
- Log Information. When you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Site.
- Information Collected by Cookies, Web Beacons and Embedded Scripts. We and our service providers use various tracking technologies, including cookies, web beacons and embedded scripts, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites. Web beacons are small pieces of data that are embedded in images on the pages of web sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy practices. We may use web beacons to bring together information we collect about you and to help us optimize and tailor our Sites for you and other future visitors to our Sites. An embedded script is programming code that is designed to collect information about your interactions with our Sites, 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 Sites, and is deactivated or deleted thereafter.
1(b). Information We Collect From Third Parties
We may receive information that third parties provide us, which may include information about you. For example, we may collect information about you when you engage third parties to assist in ordering our products or services, when we use third parties to validate or update your information or other third parties who offer services that integrate with the Sites. Additionally, we may collect information about you when you post content to our pages or feeds on third party sites. This Privacy Policy does not apply to information collected through or by any third party. If you have any questions about such third parties’ privacy practices, you should review their privacy policies.2. How Do We Use Your Information?
We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information:- To personalize the user content and experience.
- To provide, maintain and improve our Sites and provide you with relevant information and content.
- To facilitate and administer the provision of the products and services you purchase or request from us, including the verification of your identity or location, processing payment, to respond to any communications from you, or to administer a survey, promotion, sweepstakes or contest you participate in.
- To contact you in connection with your account, a particular activity, purchase, or product or service, in person or by recorded message, by e-mail, telephone and/or mobile telephone number, text (SMS) message, or any other means of available communication.
- To notify you in connection with a survey, promotion, sweepstakes or contest.
- To provide you with information and offers on our products and services, that we believe may be of interest to you.
- To send you technical notices, updates, security alerts and support and administrative messages.
- To respond to your comments, questions and requests and provide customer service, including through any website chat function, whether automated or not.
- To monitor and analyze trends, usage and activities in connection with our Sites.
- To protect our rights and property and the rights and properties of others.
- To maintain appropriate records for internal administrative purposes.
- To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.
- To link or combine with information we get from others to help understand your needs and provide you with a better experience.
- To carry out any other purpose described to you at the time the information was collected.
- To comply with legal and regulatory requirements (including fraud prevention and anti-money laundering), required disclosures and choices and controls that may be available.
- To comply with our obligations to third parties in accordance with the terms and conditions of their services being provided on our behalf or directly to you.
- Detect, investigate or prevent activity that may be illegal, violate our policies, cause harm to our operations or compromise our security.
- To carry out debt-recovery functions.
- For any purpose that, under the circumstances, would be reasonably expected by a consumer to be employed.
- To train our staff.
- For any other purpose with your consent.
Third Party Analytics Services. We may work with certain third party service providers to collect, analyze, and use some of the information collected from you. For example, we may allow our service providers to set cookies or use web beacons on the Sites or in email communications from us, including Google, Inc.’s Google Analytics and AdWords services, Commission Junction LLC, and other similar third-party vendor services. These services use cookies to transmit your IP address and other website navigation and Internet usage and network activity data and device and browser-generated data, including regarding your browsing history and your interaction with our and other websites, applications, and advertisements. These service providers may provide this data to us or store and/or aggregate this data to analyze such usage and create reports for us. These service providers may also display our ads on sites across the Internet, and they may use this data to later display ads or other information to you based on your website usage or other information collected as described above. You may be able to set your browser to remove or reject browser cookies.
We do not control these third party service providers’ tracking technologies or how they may be used.
3. Who Do We Share Information With?
We may share information about you as follows or as otherwise described in this Privacy Policy:- With vendors, consultants, business partners, our related entities, contractors, or service providers to help us operate our business and the Sites and to administer activities on our behalf, and to assist with services such as data processing and matching, data analysis, data monetization services, information broking, business consulting, and marketing/research.
- With strategic partners who provide additional features on the Sites. These strategic relationships may include business partners, sponsors and co-branded Site features. The use of your information by these third parties is subject to their own privacy practices and you should check their website for information regarding their privacy policies.
- By participating in any survey, promotion, sweepstakes or contest, you agree to the official rules that govern that survey, promotion, sweepstakes or contest, including disclosure of your information to third parties or the public in connection with the administration of such survey, promotion, sweepstakes or contest, or as required by law.
- As may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Use, or activity that appears to us to be illegal or may expose us to legal liability.
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process.
- As determined necessary to protect the rights, safety, or property of any person or as otherwise appropriate when we believe your conduct on the Sites is inappropriate, is detrimental to us, or is inconsistent with generally accepted norms of behavior.
- In the event that we, or any of our businesses, are being sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership.
- In connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
- To enforce any agreement we may have with you.
- Between and among us and any current or future parent, subsidiary and/or affiliated company.
- To fulfill the purpose for which you provided such information.
- For any other purpose disclosed by us when such information was collected.
- With your consent or at your direction.
- As otherwise would, under the circumstances, be reasonably expected by a consumer.
4. Protection of Information
We maintain reasonable physical, operational and electronic security measures to protect your information. However, the transmission of information via the Internet, the Sites or email is not completely secure and we cannot guarantee the security of information transmitted to or from us. Your use of the Sites and provision of information to us indicates that you are willing to assume this risk. Access to personal information is limited to those with a specific “need to know” in order to provide products and services to policyholders and to others as permitted or required by law. We maintain contractual, physical, electronic and procedural safeguards to protect against the misuse of personal information under our control. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Travelex Insurance encourages you to learn as much as you can about your privacy on the Internet.In specific circumstances we may also retain your personal data for extended periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
We maintain a data retention policy which we apply to records in our care. Where your personal data is no longer required we will undertake reasonable efforts ensure it is either securely deleted or stored in a way which means it will no longer be used by the business. We may also use your information in connection with promotional or marketing efforts, for example:
5. Links to Third Party Sites
Our Sites may link to other websites whose privacy practices may differ from ours. If you submit information to any of those websites, your information is governed by their privacy statements. We do not exercise control over third-party websites and are not responsible for the privacy practices or the content of any such third-party websites. We encourage you to carefully read their privacy statement. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third party, nor is it an endorsement of their privacy or information security policies or practices.6. Notice to International Users
The Sites are hosted in the United States and are subject to U.S. law. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the transfer to and processing of your personal information in the U.S.7. Children’s Privacy
The Sites are intended for general adult audiences, and you represent that you are over the age of majority in your jurisdiction of residence. If we have any reason to believe you are not the age of majority or older we may terminate your access to the Sites. In the event that we collect personal information from children under the age of 13 in connection with providing our products or services, we require such personal information to be provided from a parent, guardian or other person with legal authority to provide us with such information. For example, if you purchase a product from us that includes coverage for a child under the age of 13, we may require the child’s name and data of birth. We do not share, sell, rent or transfer children’s personal information other than as set forth in this Privacy Policy.8. Disputes
9. Consumer Privacy Rights
The law of your jurisdiction may provide you with certain rights regarding our use of your personal information. Subject to any exceptions under applicable law, you may have the following rights with respect to your personal information collected by Travelex Insurance:- The right to know and access. You may have the right to request Travelex Insurance provide you with (i) a copy of the personal information that we have collected or maintained about you during any specific period of time; (ii) the categories of personal information that we have collected or maintained about you during any specific period of time; (iii) the categories of purposes for which such personal information was disclosed during any specific period of time; (iv) the categories of sources of such personal information that was collected during any specific period of time; and (v) the categories of third parties that such personal information may have been shared with during any specific period of time. If you exercise your right to know or access, we will endeavor to provide you with the information requested for the specific time period requested. If you choose to exercise your right to know or access and do not specify a time period, we will endeavor to provide all of the requested information collected or maintained after January 1, 2022, unless doing so would be impossible or involve a disproportionate effort. In the case that fulfilling a request to know or access proves impossible or involves a disproportionate effort, we will endeavor to provide you the requested categories of information collected or maintained by Travelex Insurance in the immediately preceding 12 months from the date of your request. All information provided to you under this right to know and access will be provided in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format that will allow you to transmit the relevant information to another entity without hindrance or impediment.
- The right to deletion. You may have the right to request that Travelex Insurance delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations, complete a transaction for which your personal information was collected, or if such deletion would be impossible or require a disproportionate effort. If we are unable to comply with your request for deletion, we will let you know the reason why.
- The right to correct inaccurate personal information. You may have the right to request that any of your inaccurate personal information that is maintained by us to be corrected, taking into account the nature of the personal information and the purposes of the processing of the personal information.
- The right to portability. You may have the right to request that Travelex Insurance transmit your personal information to another entity in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format.
- The right to not be subject to certain profiling. You may have the right to opt-out of processing of your information which constitutes profiling in furtherance of decisions that produce legal effects or similarly significant effects concerning you. By using the Sites, applying for insurance coverage, maintaining insurance coverage, or otherwise communicating consent to automated decision making, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the use of automated decision making and profiling for the provision of our services. If you do not consent to the use of automated decision making and profiling, then we cannot provide our insurance services to you, and you must not engage with the Sites or use our insurance services. If you are a current or prospective plan holder and you wish to revoke your consent to the use of automated decision making and profiling, please contact us at [email protected] or 888-744-6564 and we will cancel your insurance policy or application, as applicable.
- The right to appeal. If you submit a request to exercise one of the above rights and we deny such request, you may have the right to appeal our decision.
- The right to file a complaint. You may have the right to file a complaint with a relevant supervisory authority or your state’s Attorney General. You may contact us, the relevant supervisory authority, or your state’s Attorney General for more information. Click here for state specific information.
If you choose to exercise any of these foregoing rights, we will not discriminate against you in any way. However, if you exercise certain rights, you may be unable to use or access certain features of the Sites or receive certain services.
9(a). Exercising Consumer Rights
To exercise any of these rights, contact us at [email protected] or 888-744-6564. In connection with submitting a request, you must provide the following information, as applicable: name (first and last), email address, phone number, state of residence, and policy number (as applicable) and you must state what type of request you are making.9(b). Disclosure of Personal Information
We may have collected and disclosed the following categories of personal information from a consumer for a business purpose in the preceding 12 months:- Various identifiers, including, name, address, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.
- Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information, including, behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information.
- Internet or other similar network activity, including, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data in order to analyze trends in the aggregate and administer our Site.
- Geolocation data, including, physical location or movements.
- Sensory data, including, audio, electronic, visual, or similar information.
- Professional or employment-related information, including, current or past job history or performance evaluations.
- Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.
- Inferences drawn from other personal information, including, profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, attitudes, intelligence, abilities, and aptitudes.
- Protected classification characteristics, including, race, color, national origin, marital status, sex, veteran or military status.
- Personal records, such as, power of attorney, family history or power of attorney.
- Information received from a government entity or other third party.
- Sensitive personal information, including: (a) a consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data.
9(c). Sale and Sharing of Personal Information and Use of Sensitive Personal Information
Travelex Insurance has not, in the preceding 12 months, and does not currently, sell or share your personal data for money or other valuable consideration.9(d). “Shine the Light” Law
California’s "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California consumers asking about the business' practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to [email protected].10. Nevada Resident Privacy Rights
Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised Statutes Chapter 603A. However, please know Travelex Insurance does not currently sell data triggering this Nevada statute's opt-out requirements. If you have questions with respect to this right, please contact [email protected].11. Your Choices
- Location Information. With your consent, we may collect information about your actual location when you use our mobile applications and when you request or purchase products or services. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so.
- Native Applications on Mobile Device. Some features of our mobile applications may require access to certain native applications on your mobile device, such as the camera, photo album and the address book applications. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting associated information. Note that you can revoke your consent at any time by changing the settings on your device.
- Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.
- Push Notifications. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.
- Direct Mail Marketing. To request to opt out of receiving unsolicited commercial direct mail please contact [email protected].
- Email Marketing. You can choose to opt out of receiving promotional emails from Travelex Insurance at any time. Emails will include an unsubscribe link that will remove you from future emails. You may also submit a request to [email protected].
12. Your Rights
To the extent that the General Data Protection Regulation of the EU (GDPR), or some other privacy related law that includes similar rights applies to our processing of your personal data not otherwise addressed herein - you may have several rights, of which we would like to inform you; the right to access your data, the right of data rectification (if your data is inaccurate), the right of erasure (if the retention of your data is no longer necessary in relation to the envisaged purpose of the processing), the right to restrict the data processing (e.g. if you contest the accuracy of your data that we process), the right to data portability and the right to lodge a complaint with the competent supervisory authority. At any time during which your data is processed by us, you can withdraw your consent to the processing by reaching out to Zurich and request the data deletion.
You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making or the basis for international transfers. You may also exercise a right to complain to your Supervisory Authority. More information about each of these rights can be found by referring to the table set out further below.
To exercise your rights you may contact us as set out in Section 14. Please note the following if you do wish to exercise these rights:Right | What this means |
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Access | You can ask us to:
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Rectification | You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it. |
Erasure | You can ask us to erase your personal data, but only where:
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request. |
Restriction | You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
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Portability | You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where:
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Objection | You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. |
Automated Decision Making | You can ask not to be subject to a decision which is based solely on automated processing (see Section 2), but only where that decision:
In such situations, you can also obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision. |
International Transfers | You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred to third parties in other countries. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity. |
Supervisory Authority |
You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO (https://ico.org.uk/). We ask that you please attempt to resolve any issues with us first although you have a right to contact your supervisory authority at any time.
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Identity | We take the confidentiality of all records containing personal data seriously, and reserve the right to ask you for proof of your identity if you make a request in respect of such records. |
Fees | We will not ask for a fee to exercise any of your rights in relation to your personal data, unless your request for access to information is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request. |
Timescales | We aim to respond to any valid requests within one month unless it is particularly complicated, or you have made several requests in which case we aim to respond within three months. We will let you know if we are going to take longer than one month. We might ask you if you can tell us what exactly you want to receive or are concerned about. This will help us to action your request more quickly. |
Third Party Rights | We do not have to comply with a request where it would adversely affect the rights and freedoms of other data subjects. |