Privacy Statement (EN)

This Privacy Notice is issued by Travelex Currency Exchange & Payments Sdn Bhd (818930-H) (“Travelex”, “we”, “us” or “our”).

Travelex Currency Exchange & Payments Sdn Bhd Privacy Notice: last updated in December 2018

Important Note: If you deal with or through Travelex, you consent to Travelex’s use of Personal Data in accordance with this Privacy Notice. Therefore please read it carefully.

1. Our Contact Details

If you need to contact us, you may visit any of our branches, call our office at +60 3 2281 3000, or visit us at www.travelex.com.my.

2. Definitions

Unless the context otherwise required, capitalised terms used herein have the following meanings: “Personal Data” means any information in respect of Transactions which relates directly or indirectly to you and: 

1. is processed by or through Travelex;
2. is recorded by Travelex;
3. identifies you or renders you identifiable; and
4. Includes Sensitive Personal Data and expressions of opinion about you.
   
   Without limiting the foregoing, Personal Data may include: 
   1. information about you including your age, marital status and financial status; 
   2. transactional information about our services and how you use them; 
   3. information you share with us when you contact us for any reason (including through social media); 
   4. information when you take part in promotions, competitions, surveys or loyalty schemes; 
   5. details of your visits to our website. This includes which website you came from, pages you viewed during your visit, and the page you viewed after you left; 
   6. data collected by cookies and corresponding technologies, together with the personal information we have collected; and 
   7. CCTV images where available. 

“Sensitive Personal Data” means any Personal Data which includes information about your physical or mental health, political opinions, religious or other beliefs and the commission or alleged commission by you of any offence.

“Transactions” means any commercial transactions you undertake with or through Travelex in relation to our foreign exchange products and services, regardless of the channel used by you.

"Travelex" or "we" or “us” in this Privacy Notice refers to Travelex Currency Exchange & Payments Sdn Bhd, including where the context requires, its branches, affiliates and related entities outside Malaysia.

3. Purpose of this Privacy Notice

This Privacy Notice outlines how Travelex: 

1. collects, uses, maintains and discloses Personal Data in respect of Transactions;
2. safeguards Personal Data.

4. How Personal Data is provided to us

Personal Data may be provided to us:

1. by you when you deal with the Travelex (for example, by purchasing products from us, registering an account on our website, contact us through any channel, participate in surveys or competitions);
2. by a third party (for example your spouse, a company in which you are a director, an officer or a shareholder, or a partnership in which you are a partner) for products or services that these third parties have sought from Travelex; and
3. Through other means (for example, from our analysis of your transactions, video recordings from close circuit security surveillance cameras, audio recordings of taped telephone conversations or publicly available sources).

5. The purposes for which we will use Personal Data

We will only use Personal Data (which, as a reminder, includes Sensitive Personal Data) for legitimate purposes related to the conduct of our business and the processing of Transactions. This includes the following:

1. provide the products and/or service(s) you signed up for;
2. collect payment;
3. process and fulfil your order, provide order tracking facilities, or otherwise provide you with the information, products and services you may request from us;
4. Complying with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This may include checking the information you provide to us against information from other sources;
5. enforce any contract entered into between you and us in respect of the Transactions;
6. send you marketing messages;
7. dispute and complaints resolution;
8. provide you with service messages (for example, by notifying you regarding changes to our our terms, conditions and policies);
9. improving customer experience and our quality of service;
10. data analysis;
11. enable us and third party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or any other relevant information;
12. fraud prevention or detection;
13. verify your financial standing through credit reference checks;
14. manage and maintain your account and facility; and
15. Security reasons (in particular personal data collected from close circuit security surveillance cameras).

6. Can you refuse to provide us with Personal Data?

Yes.

You have the choice, at any time, not to provide your Personal Data to us.

However if you do not provide the information we require to process a Transaction, resolve a complaint, provide you with products and services or otherwise deal with you for the purposes contemplated, we may not be able to do the aforementioned things.)

7. Do you have to provide us with Personal Data to receive our products and services?

Not necessarily.

The Personal Data we collect can be either obligatory or voluntary. Obligatory Personal Data is data we require in order to provide you with our products and services. Voluntary Personal Data is data which is not required in order for us to provide you with our products and services. We will where practicable, indicate which type of data is being requested by us.

8. Can we share your Personal Data?

Yes.

From time to time, we may share your Personal Data with:

• other entities within Travelex;
• our agents;
• subcontractors;
• service providers;
• regulatory, governing and judicial bodies;
• credit reference agencies when you apply for any of our credit-based products;
• financial service providers;
• parties authorised and consented to, by you;
• advisors; and
• Where reasonably necessary for any of the purposes mentioned herein (and on the understanding that any such entity will treat the information as confidential) strategic partners ("Other Entities").

9. Can your Personal Data be transferred outside Malaysia?

Yes.

This may be done for various legitimate business purposes including storage, verification, processing transactions, conducting investigations and governance.

10. Can we use your Personal Data to send marketing material to you?

Yes.

You may receive marketing communication from us or Other Entities. If you no longer wish to receive these marketing communications, you may opt out or notify us (noting that it can take up to 14 days for such withdrawal to be reflected in our systems). Please note that even if you opt out from receiving marketing or promotional materials, Travelex may still contact you for other purposes in relation to the accounts, facilities or services that you hold or have subscribed to with Travelex.

11. How do we protect your data?

Travelex takes all physical, technical and organisational measures needed to ensure the security and confidentiality of Personal Data. If we disclose any of your Personal Data to our authorised agents or service providers, we will require them to appropriately safeguard the Personal Data provided to them.

12. How long may we retain your personal data?

We will retain your personal data for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal corporate governance requirements.

13. Changes to this Privacy Notice

Please note that we may update this Privacy Notice from time to time. If there are material changes to this Privacy Notice, we will notify you by posting a notice of such changes on our website or by sending you a notification directly. Do periodically review this Privacy Notice to stay informed on how we are protecting your information.

14. How can you access / correct / update your personal data?

If there are any changes to your Personal Data or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal data. You have the right to access your Personal Data. If you would like to request access to your Personal Data, please contact us. Please note that depending on the information requested we may charge a small fee. We may also take steps to verify your identity before fulfilling your request for access to your Personal Data.

15. Third Party Personal Data

If you have provided Travelex with Personal Data of a third party, please ensure that you have obtained the third party's consent in relation to the processing and disclosure of their Personal Data and that this Privacy Notice is brought to the attention of any such third party. If you have any concerns about Travelex’s processing of the Personal Data of such third party, please contact us.

16. Other Contracts

In case there are inconsistencies on how we collect or use your Personal Data between this Privacy Notice and the terms and conditions of your specific product or service or other contractual documents, the terms and conditions of your specific product or service or other contractual documents shall prevail.

17. Bahasa Version

We provide the Privacy Notice in both English and Bahasa Malaysia. In case of any inconsistencies between these two, the English version shall prevail.