Travelex Insurance Privacy Policy

Effective Date: October 14, 2025

Travelex Insurance Services, Inc. ("Travelex Insurance", “we”, "us" or "our") respects your right to privacy. This Privacy Policy is designed to inform you about how we collect, use and share information about you, including in person, by phone, through mail or email or through our website www.travelexinsurance.com, and any other Travelex Insurance-owned and/or operated website, mobile sites, mobile applications or social media accounts (collectively, our "Sites”).

Table of Contents

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
Your State Privacy Rights and Additional Disclosures
California Resident Privacy Rights
Universal Opt-Out Mechanisms
Notice of Financial Incentive/Loyalty Program
Your Choices
Your Rights
Changes to Privacy Policy
Accessibility
Contact Us

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. Categories of information we may collect from you include:

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 email 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. If you use our Travelex chatbot feature, you will provide us with your name, plan code, phone number, and any additional information you choose to provide in your chat messages. Our Travelex chat feature is provided by Talkdesk, Inc. Talkdesk, Inc. may collect, record, and store the information you provide in the chat. Please review Talkdesk, Inc.’s privacy policy here.
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.

Information We Collect Automatically

We and our third-party 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. We collect location information from visitors to the Sites on a city-regional basis. With your permission, we may also collect information about the precise geolocation 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 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 provider, is active only while you are connected to the Sites and is deactivated or deleted thereafter.

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, such as sanctions lists, 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.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may aggregate data in order to improve our automation and improve user experience. Such de-identified and/or aggregated information is not subject to this Privacy Policy.

Electronic Promotional Messages. We may send you promotional emails regarding special offers about our or our affiliates’ products and services or products and services on behalf of third-party marketing partners who we think can offer products, services or content of interest to you. If you do not wish to receive information from us regarding special promotions or offers you can opt out of receipt of such promotional mailings (please see "Your Choices" below). Even if you opt out of receiving promotional emails we may continue to send you transactional notifications that are related to your account, orders, or other products or services you have requested.

Direct Mail Promotional Offers. We may use your name and mailing address which we obtain from you for us, our affiliates or third-party marketing partners to provide marketing offers to you through direct mail. If you prefer not to have your name and mailing address shared with a third party in connection with direct mail promotional messages please see "Your Choices" below). Please note that even if you opt out of receiving promotional mail we may continue to send you transactional notifications in the mail that are related to your account, orders, or other products or services you have requested.

Third-Party Analytics Services. We may work with certain third-party providers to collect, analyze, and use some of the information collected from you. For example, we may allow third-party 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 providers may provide this data to us or store and/or aggregate this data to analyze such usage and create reports for us. These 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 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 business partners and our related entities (e.g., Zurich American Insurance Company, World Travel Protection Canada Inc.) to provide our services to you.
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.
If you participate in any survey, promotion, sweepstakes or contest, we may disclose 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.

Affiliated and non-affiliated third parties that may receive or have access to the personal information in our care are not authorized to use such information for any marketing purposes except as permitted by law or with your consent. They may not copy or disclose personal information to any other party and may use it only for the purpose of performing their responsibilities to us, one of our policyholders and as otherwise permitted or required by law. Consent. Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of personal information may be required. This consent can be, in some circumstances, express (oral or written) or implied. Your consent may be withdrawn, subject to legal or contractual restrictions. By providing your personal information to us as part of a request that we provide a plan, product, or services, or as a request for employment and employment related benefits, you are implied to have consented to the transfer of your personal information to affiliated and unaffiliated third parties as may be necessary to provide the plan, service, or employment and benefits that you have requested.

4. Protection of Information

We maintain commercially reasonable security measures to protect the information we collect and store from loss, misuse, destruction, or unauthorized access. However, no transmission of information via the Internet, the Sites or email is completely secure and we cannot guarantee the absolute security of information transmitted to or from us. Travelex Insurance encourages you to learn as much as you can about your privacy on the Internet.

Record Retention. We will maintain your information, including any sensitive personal information, for only as long as reasonably necessary to fulfil the purpose for which it was collected, and as long as legally necessary, in accordance with applicable law. In some circumstances we may retain your personal information for extended periods of time, for instance, where we are required to do so in accordance with legal, regulator, tax or accounting requirements. For example, some insurance related insurance information must be retained for seven (7) years. Some contracts require a longer retention period.

In specific circumstances we may also retain your personal information 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 information or dealings.

We maintain a data retention policy which we apply to records in our care. Where your personal information 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.

5. Links to Third-Party Websites

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.

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.

7. Children’s Privacy

The Sites are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13. In the event that we collect personal information about 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.

8. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “Notice to California Residents” section below. For other state residents, your privacy rights may include (if applicable):

The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data;
The right to obtain a list of categories of third parties to which we have disclosed your personal data;
The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
The right not to receive discriminatory treatment by us for the exercise of your privacy rights

We use cookies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. When we engage in those activities, we sell personal data (i.e., information from cookies) to third-party advertisers and analytics companies.

9. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

9(a). Notice at Collection of Personal Information

We may collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

Various identifiers, including, name, address, online identifier, email address, account name, and other similar identifiers.
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number and financial information.
Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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, 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 precise 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.

We may collect the above categories of Personal Information directly from you, indirectly as you interact with our Sites, from or through other third-party sources, including our customers, or through email or other electronic messages between you and our Sites. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How Do We Use Your Information?” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
Debugging to identify and repair errors that impair existing intended functionality
Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service, and to improve, upgrade, or enhance the service
Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction

9(b). Sale, Sharing, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites.

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Category of Personal Information	Categories of Third Parties
Various identifiers (online identifier) Internet or other similar network activity	Data analytics providers Advertising networks Social networks

We sold or shared Personal Information to third parties for the following business or commercial purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Advancing our commercial or economic interests, such as by enabling or effecting, directly or indirectly, a commercial transaction

We disclosed the following categories of Personal Information to service providers or contractors for a business purpose in the 12 months preceding the Last Updated Date of this Privacy:

Various identifiers (name, address, online identifier, email address, account name, or other similar identifiers)
Telephone number
Financial information
Commercial information (records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Sensory data, including, audio, electronic, visual, or similar information

We disclosed Personal Information for the following business or commercial purposes:

Storing data, providing products and services, processing payments, complying with applicable laws and regulations, improving products and services based on customer feedback and data.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

Retention of Personal Information

We retain your Personal Information as described in the above "Record Retention" section.

9(c). Your CCPA Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
The right to delete Personal Information that we collected from you, subject to certain exceptions;
The right to correct inaccurate Personal Information that we maintain about you;
If we sell or share Personal Information, the right to opt out of the sale or sharing;
If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
The right not to be retaliated against for exercising privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct by emailing us at [email protected] or by calling us toll free at 1-888-744-6564. In connection with submitting a request, you must provide the following information, as applicable: name, email address, phone number, state of residence, and policy number and you must state what type of request you are making.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

9(d). Sale and Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by emailing us at [email protected] or by calling us toll free at 1-888-744-6564. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Universal Opt-Out Mechanisms” section below for more information.

We do not use your sensitive Personal Information for the purpose of inferring characteristics about you or for purposes other than those allowed by the CCPA and its regulations.

10. Universal Opt-Out Mechanisms

The Sites recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

11. Notice of Financial Incentive / Loyalty Program

From time to time, you may have the opportunity to provide personal information in exchange for certain incentives. For example, when you subscribe to a newsletter or email list, you are exchanging personal information with us for certain incentives. When you subscribe to a newsletter or email list, you will provide us with your contact information such as your name, mailing address, and email address. We also offer promotions in exchange for you participating in our surveys, contests, and sweepstakes. Categories of personal information that we may collect when you participate in these promotional events include your name, email address, mailing address, telephone number, and other information depending on the promotion. We may use all of these categories of personal information for targeted advertising purposes.

Disclosures to Third Parties

We disclose these categories of personal information to third parties including our affiliates, vendors, analytics companies, third-party marketers, data brokers, and social networks.

How to Opt In and Right to Withdraw

Signing up for our incentives is optional. By entering yourself into a survey, contest, sweepstakes, or other promotional event, you affirmatively opt in to participating in the respective promotional event(s). You have the right to withdraw from these incentives at any time. If you wish to withdraw from our marketing lists, you can “unsubscribe” through our emails. You can withdraw from contests, and giveaways at any time by contacting us at [email protected]. Please note that if you request that we delete your personal information, then we will no longer be able to provide you with the same incentives and benefits. We must maintain the personal information that you provide for us to provide the incentives and program benefits to you.

How the Incentive is Reasonably Related to the Value of Your Personal Information

The incentive is reasonably related to the value provided by your personal information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any incentive. Based on this analysis, the value of your personal information that allows us to make these offers and incentives is the value of the offer itself.

12. 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. Marketing emails will include an unsubscribe link that will remove you from future emails. You may also submit a request to [email protected].

13. Your Rights - EEA and UK Only

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 the “Contact Us” section below. Please note the following if you do wish to exercise these rights:

Right	What this means
Access	You can ask us to: Confirm whether we are processing your personal data; Give you a copy of that data; Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.
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: It is no longer needed for the purposes for which it was collected; or You have withdrawn your consent (where the data processing was based on consent); or Following a successful right to object (see 'Objection' below); or It has been processed unlawfully; or To comply with a legal obligation to which Travelex Insurance is subject. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: For compliance with a legal obligation; or For the establishment, exercise or defense of legal claims. 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: Its accuracy is contested (see Rectification), to allow us to verify its accuracy; or The processing is unlawful, but you do not want it erased; or It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or You have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal data following a request for restriction, where: We have your consent; or To establish, exercise or defend legal claims; or To protect the rights of another natural or legal person.
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: The processing is based on your consent or on the performance of a contract with you; and The processing is carried out by automated means.
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: Produces legal effects concerning you (such as the rejection of a claim); or Otherwise significantly affects you. 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. Your right not to be subject to automated decision making does not apply where the decision which is made: Is necessary for entering into or performing a contract with you; Is authorized by law and there are suitable safeguards for your rights and freedoms; or Is based on your explicit consent. 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.
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.

14. Changes To This Privacy Policy

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on our Sites, with a posted "Last Updated Date". Please review this Privacy Policy periodically.

15. Accessibility

We are committed to facilitating the accessibility of our Sites for all people with disabilities. To access this Privacy Policy in an alternative format, please contact us at [email protected] or 1 844-246-8480.

16. Contact Us

If, at any time, you would like to access, change, or request deletion of your personal data (please specify the kind of information you are seeking and provide your name, email address, phone number, state of residence, and policy number, as applicable), or if you have questions, concerns, complaints, or comments about our Privacy Policy, please feel free to contact our privacy manager at [email protected] or write to us at: Privacy Manager Travelex Insurance Services, Inc 810 N. 96th Street, Suite 300 Omaha, NE 68114 If you have a complaint or concern about how we use your personal data, please contact us, and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.