Travelex Currency Exchange (China) Limited Privacy Notice

Travelex Currency Exchange (China) Limited (“Travelex” or “we” or "us" or "our") is a subsidiary of the Travelex Group who is a world-wide foreign currency exchange specialist. Travelex is a licensed money service provider in the People’s Republic of China (PRC), and also the owner and operator of this website  www.travelex.com.cn ("Website"). This privacy notice is issued by Travelex in accordance with all relevant data protection laws of the including the Personal Information Protection Law of the People’s Republic of China (Chairman’s Order No. 91), the Data Security Law and Cybersecurity Law (“Data Protection Laws”).

Please read the following terms and conditions carefully. All references to “you” or “customers” in this Privacy Notice refer to visitors to the Website or customers transacting through our branch network or website

1.       Introduction

Travelex recognises the importance of safeguarding the personal information of its customers. This Privacy Notice sets out the basis on which any personal information will be collected, used, disclosed and stored by us and reflects Travelex's commitment to maintain the confidentiality of personal information. It will apply to any personal information you provide to us in the course of your dealings with us, including but not limited to, the personal information provided to us through the website or when you purchase currency at our in-store bureaux or contact us via Wechat.

2.       Collection of Personal Information

You may be asked by one of our staff at our store or prompted at various points on the Website to provide us with your personal information (including but not limited to your name, phone, postal address, email address, gender and details of your visits to the Website). For example, we may collect your personal information when you:

• provide information on the online ordering screen of the Website;
• conduct in-store transactions with Travelex; or
• participate in Travelex prize draws, competitions, online surveys or other marketing activities.

3.       Type and Scope of Personal Information

We may collect any of the following when you purchase or sell foreign currency from/to us:

Full name, date of birth, gender, nationality, ID type and ID number, ID issuing country/expiry date, address, use of fund details, email address, ID copies and other information required by law for foreign currency exchange in PRC and/or for the purpose of provision of our services to you. 

4.       Sensitive Information

We do not usually collect personal sensitive information (e.g. religious beliefs, criminal record, physical or mental health, or sexual orientation).  

We do not normally accept transactions performed by minors who are 16 or less and thus will not collect or retain such sensitive information.

We will not collect and process your personal sensitive information unless we have a specific, necessary and legitimate purpose for which processing of such information is necessary, we have informed you why it is necessary and we have obtained your separate consent. Where laws and regulations provide that the processing of your sensitive personal information shall be subject to any other relevant legal permission or other restriction, such provisions shall prevail.

Furthermore, we implement measures to safeguard the security of your sensitive personal information which are described in the ‘Protection of Information’ section below.

5.       How We Collect Personal Information

• We may ask you to complete a form or allow us to take copies of your documents when you visit our bureaux in person
• Via an online form when you reserve currency on our website
• Via Wechat when you use the app to reserve currency

6.       Use of Personal Information

We may use your information for the following purposes:

To provide a requested service or carry out a contract with you:

• considering whether to accept your orders or provide our products or services to you;
• complying with your order or providing the products and services that you request;
• administering and managing the provision of our products and services;
• responding to queries, complaints or providing you with our general customer service.

Where we have a legal obligation or right:

• notifying you about changes to our products or services;
• complying with our legal and regulatory obligations (e.g. meeting the disclosure requirements of any law binding on Travelex or any of its branches. For certain types of transaction we may be required by law to take a copy of your identity document. We collect this for the sole purpose of fulfilling the regulatory requirements in the PRC for foreign currency exchange service providers);
• verifying your identity or transactions which you may enter into with us;
• assisting other financial institutions in conducting credit checks or collecting debts;
• conducting research and analysis;
• protecting against fraud;
• enforcing or protecting the rights, property, or safety of Travelex, our customers, or others (including, but not limited to, collecting any money you owe us) or.Where we have your consent:
• sending you Travelex’s market commentaries, newsletters or similar materials;
• promoting and marketing our products and services to you and informing you of our special offers, promotions or competitions;

You have the right to withdraw your consent at any time. For details of how to do this, see the ‘Your rights’ section below.

7.       Disclosure of Personal Information

We will not disclose your personal information unless we have obtained your consent to disclose except in the following circumstances:

• the disclosure is required or authorised by law, for example, disclosing your personal information to government or regulatory bodies for purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue;
• criminal investigations, prosecutions, trial and judgment enforcement;
• In order to fulfil the provisions of anti-money laundering and sanctions laws and regulations;
• you have made the personal data publicly available; or
• we have obtained your personal data from lawful public sources, such as legitimate news reports or open government information.

8.       International Transfers

The personal information collected and generated by us in the territory of the PRC will be processed and stored in the territory of the PRC. However, in order to provide the service for your, we may utilize Travelex Group shared services and transfer your personal information to other Travelex Group entities located outside of the PRC. This is because the information is processed in those locations for the purposes of meet our legal obligations to anti-money laundering, fraud prevention and identity validation. Please see Appendix A for further details.

Where we do so, we will obtain your separate consent, and put in place security measures and appropriate safeguards to protect your information and ensure that all transfers of your information comply with applicable Data Protection Laws. We also ensure that processing is only ever carried out in accordance with our instructions.

In all cases where we transfer information outside the PRC, we shall take necessary measures to ensure that the processing of personal information by any overseas recipients meets the personal information protection standards stipulated in the Data Protection Laws.

9.       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.

Even where shared, we ensure your information will only be used for the purposes outlined in this notice:

• We 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 privacy notice, and industry standards of confidentiality and levels of security;

use service providers that the Travelex or Travelex Group engages to do something on our behalf, such as organizations providing administrative, telecommunications, computer, payment or other services to Travelex or Travelex Group;

• We also share your information with a third party when we:

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;

if either of these happens we will inform you of the name and contact information of the data recipient.

10.   Your Rights

By law, you have a number of rights (subject to certain conditions) when it comes to your information. These include the right to ask us what information we hold about you, and to request us to modify any incorrect details, add missing information, or to delete the information we hold. You also have the right to object to us processing your data or ask us to restrict processing your information. See below for more details.

• 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 Privacy 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 Statement). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
• The right to rectification. We ensure that the information we maintain about our customers is accurate, current and complete. 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 below.
• The right to erasure. This enables you to request the deletion or removal of your information that we hold, subject to any legal obligation we have to retain records for regulatory purposes.
• he right to restrict processing. You have rights to ‘block’ or supress further use of your information. 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 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).

If you wish to access or correct your personal information or assert any other of your rights, please contact us by email or by phone. Please refer to the ‘Customer Inquiries’ section for details. Please also understand that sometimes we may not be able fulfil your request due to record keeping requirements or other restrictions imposed by laws and regulations. 

We respond to requests from customers in respect of the above rights, within 15 working days.

11.   Protection of Information

We take all reasonable steps to ensure that all information collected through our Website 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 regular review measures.

We have a number of security measures in place to protect your information you provide to us through our website 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.

12.   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) through the use of "cookies". Cookies are small pieces of information that are stored on your computer's hard drive by your browser. The information collected by "cookies" does not identify you as an individual. 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.

13.   Opting out of marketing, promotions or related activities

You may be contacted by mail, telephone or email for purposes of customer service or to be notified of related products, promotions, newsletters, customer surveys and similar materials that we may conduct or distribute from time to time in accordance with your preferences. If you do not wish to receive any such communications, you may advise us that you want to be removed from the Travelex customer database. Please refer to Customer Inquiries in section 17 below for our contact details.

14.   Storage and Retention of your Information

We only retain your information for as long as is necessary for us to use your information as described in this Privacy Notice 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 or to be able meet our contractual obligations to you, and if necessary, to resolve any disputes. We will not keep more information than we need.

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);
• limitations under applicable law(s);
• (potential) disputes; and
• guidelines issued by relevant authorities.

Otherwise, we securely erase your information once this is no longer needed.

15.   Links to Third Party Websites

Our website may, from time to time, contain links to third parties’ websites. If you follow a link to any of these websites, please note that these websites have their own privacy notices and accordingly we cannot accept any responsibility or liability for such notices. It is therefore advisable to check these policies before you submit any personal information to these websites.

16.   Changes to Our Privacy Notice

We may change the terms of this privacy notice at any time without notice. Any changes we make to our privacy notice will be posted on the website. Please do check our Privacy Statement from time to time to take notice of any changes made. By providing us with your personal information, using, visiting or browsing the website after we have changed the terms of our privacy notice, you will be deemed to have accepted these changes.

This notice was last updated March 2023

17.   Customer Inquiries

If you would like to receive further information about how your personal information is collected, used, disclosed or stored; or if you receive promotional or marketing email or mails from us and you wish to opt-out, please contact us:

• by sending us an email to ChinaDPO@travelex.com
• by mail addressed to

The Data Protection Team,

Travelex Currency Exchange (China) Limited,

Suite 603-604, Tower E2, No. 21, Lane 58, East Pan Zhong Road, Qingpu District, Shanghai, China PR

• by calling us at (+86) 21-59819271

We will respond within 15 working days after receiving your request.

If you want to contact overseas recipient, please contact:

• by sending an email to dataprotectionteam@Travelex.com
• by calling at (+44) 0345 872 7627

Appendix A – Details of Overseas Data Transfer