Worldwide Privacy Notice
The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when a Trust My Travel membership is created, test transactions are submitted through our website, the Trust My Travel form is used, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.
The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering and other harmful activity.
2. Data We Collect
a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a business applies for Trust My Travel Membership, a Customer makes payments or conducts transactions through a Member’s website or application, a person responds to Trust My Travel’s emails or surveys. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
Contact details, such as name, postal address, telephone number, email address;
Financial and transaction Data, such as credit or debit card number, and bank account information; and
Other Personal Data, such as date of birth, SSN or EIN.
b. Trust My Travel ‘Member’ vs Trust My Travel ‘Customer’, also referred to as ‘Traveller’.
Trust My Travel Processes Member data differently to Traveller personal data. Traveller data is kept securely and separated from Member data for the protection of data subject(s).
For information about how we handle historic data, notably before the imposition of the General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection on May 25, 2018 – please contact us at firstname.lastname@example.org.
c. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include:
Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using;
Transaction data, such as purchases, purchase amount, date of purchase, and payment method;
Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and
Company data, such as a company’s legal structure, product and service offerings, jurisdiction and company records.
3. How We Use Data
a. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users, Customers, and Trust My Travel; and (iv) promote, analyse and improve our products, systems, and tools. Examples of how we may use Personal Data include:
- To verify an identity for compliance purposes;
- To evaluate an application to use our Services;
- To conduct manual or systematic monitoring for fraud and other harmful activity;
- To respond to inquiries, send service notices and provide customer support;
- To process a payment using our ‘offline payment’ feature, communicate regarding a payment, and provide related customer service;
- For audits, regulatory purposes, and compliance with industry standards;
- To develop new products;
- To send marketing communications;
- To improve or modify our Services; and
- To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.
4. How We Disclose Data
Trust My Travel does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:
- a. To Trust My Travel Affiliates. We share Data with our other entities worldwide that we control, are controlled by us, or are under our common control, to provide our Services. Trust My Travel Ltd (UK) is the party responsible for overall management and use of the Data by these affiliated parties;
- b. To Trust My Travel Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, Insurers, Trustees & Payments Houses.
- c. To Our Users. We share Data with Users (such as Members and application providers) as necessary to process payments or provide the Services. For example, we share Data with Members about purchases made by Trust My Travel Customers through the online Trust My Travel dashboard.
- e. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
- f. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.
We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.
6. Choice and Access
You have choices regarding our use and disclosure of Your Personal Data:
- a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable.
- b. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.
- c. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, you may do so by signing in to your Dashboard if you are a member, or if you are a traveller, by contacting us.
- If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.
7. Retention Period
8. Use of Services by Minors
The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.
9. Jurisdiction and Cross-Border Transfer
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Your Personal Data.
10. Privacy Shield Certification
If You are located in the EEA or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of Personal Data. Trust My Travel is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.
11. Trust My Travel as a Data Processor
We may collect, use and disclose certain Personal Data about Customers when acting as the Member’s service provider. Our Members are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.
13. Contact Us
Trust My Travel Ltd
The Cedars, New Road
Attention: Trust My Travel
For EU individuals: The entity that provides Services in Europe is Trust My Travel Limited (as stated above).
Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in Your emails to us.