Privacy & Cookie Policy

Purpose & Scope

Travel Cashier, its affiliates and subsidiaries place a priority on the Data Privacy of its employees, contractors, clients, prospective clients, service providers and other partners or third parties and on the importance of compliance with Data Protection and Privacy laws worldwide. Thus, Travel Cashier has developed this Policy that outlines and explains the appropriate principles concerning collecting, processing, transferring and using an individual's Personal Data during everyday business.

In its collection, use and disclosure of Personal Data, Travel Cashier strives to balance the needs of managing its business effectively while minimising intrusiveness and complying with local legal requirements. In some countries, additional requirements beyond this policy may be applied to comply with local legislation. Data Protection and Privacy has been and will continue to be an integral component of Travel Cashier's business practices.

Definitions

1. Data Protection or Data Privacy shall mean collection, processing, use, storage, security and transmission of Personal Data in compliance with applicable law and this Policy as outlined below.
2. Data Subject means the individual natural person associated with any Personal Data (i.e., employee, temporary employee, applicant, clients/client employees, contractors, service providers or potential clients/client employees or other partners to the extent that Personal Data is being collected).
3. Personal Data means any information relating to a natural person who is identified or is identifiable by some number or characteristic, including data on current, past and prospective employees, customers, clients/client employees, prospective clients/client employees, agents, contractors, service providers and other partners or third parties. Examples may include: name, e-mail, postal address, personal telephone number, employee number, Social Security/national ID number, birth date, salary, stock information, job level, benefits, family information, jobs history, training history, address details, telephone numbers, background checks and drug testing to the extent permitted by local law, details on business cards, etc. It doesn't cover truly anonymous information - but if you could still identify someone from the details, or by combining it with other information, it will still count as personal data.
4. Processing Personal Data (processing) means any operation or set of operations, which is performed upon Personal Data (whether or not by electronic or manual means). This includes collection, recording, copying, filing, organizing, storage, adaptation, alteration, retrieval, consultation, use and disclosure by transmission, dissemination, or otherwise making available Personal Data. It also includes the alignment or combination, blocking, erasure or destruction of Personal Data.
5. Sensitive Data is a subset of Personal Data and (subject to local requirements) may include but are not limited to race or ethnic origin, religious or philosophical beliefs, political affiliations/opinions, trade union membership, health information, sexual orientation, disabilities, certain types of personal financial data, etc.

Data Protection Act and GDPR

The DPA 2018 sets out the data protection framework in the UK, alongside the UK GDPR. The UK GDPR is the UK General Data Protection Regulation. It is a UK law which came into effect on 01 January 2021. It sets out the key principles, rights and obligations for most processing of personal data in the UK, except for law enforcement and intelligence agencies. The DPA 2018 sets out the framework for data protection law in the UK. It updates and replaces the Data Protection Act 1998 and came into effect on 25 May 2018. It was amended on 01 January 2021 by regulations under the European Union (Withdrawal) Act 2018, to reflect the UK's status outside the EU.

It sits alongside and supplements the UK GDPR - for example by providing exemptions. It also sets out separate data protection rules for law enforcement authorities, extends data protection to some other areas such as national security and defence, and sets out the Information Commissioner's functions and powers.

The UK GDPR has set out seven key principles that are further explained in the data protection and privacy principles section:

1. Lawfulness, fairness and transparency
2. Purpose limitation
3. Data minimisation
4. Accuracy
5. Storage limitation
6. Integrity and confidentiality (security)
7. Accountability

The Information Commissioners Office (ICO)

The Information Commissioner's Office (ICO) regulates data protection in the UK. The ICO offers advice and guidance, promotes good practices, monitors breach reports, conducts audits and advisory visits, addresses complaints, monitors compliance, and takes enforcement action when necessary.

Additionally, the ICO cooperates with data protection authorities in other countries, including the European Data Protection Board (EDPB), which comprises representatives from data protection authorities in each EU member state.

All entities that handle personal data must be registered with the ICO. Travel Cashier Ltd is registered with the ICO under registration number ZB459729.

Information Obtained During Customer Interactions

We respect your right to privacy in all interactions with our Services and strive to be transparent about the information we collect and how we use it. We only collect and use personal information when it is lawful for us to do so. For more information regarding the collection of Personal Data by UK entities, please visit the Information Commissioner's Office (ICO) website at https://ico.org.uk.

When you use our service or contact us, we may request and record personal data such as your name, address, date of birth, ID details, source of funds, source of wealth, email address, and telephone number. Additional information may be requested based on our risk profiling. We may also use third-party software to conduct background checks to verify the provided information and to determine if you are sanctions match or a politically exposed person.

Our corporate affiliates and third-party payment processors may collect and store billing address and credit card information on our behalf for customers who purchase services.

Our servers automatically log information when you use the Services. This includes data your browser provides whenever you visit a website or use a mobile app, such as your Internet Protocol (IP) address, the URL of the website you visited before using the Services, your browser type and settings, the date and time of your use, details about browser plug-ins and configuration, your preferred language, and cookie data.

We may also collect data about the device you use to access the Services, including its type, operating system, device settings, application IDs, unique device identifiers, and crash data. Depending on your device type and settings, some or all of this data may be collected.

For security purposes, the safety of our employees, and to assist in the prevention of crime and fraud, we may use CCTV to gather information about you when you visit our stores.

Data Protection & Privacy Principles

The Data Protection and Privacy principles below are the foundation of this Policy. As such, Travel Cashier Ltd will, through appropriate management and controls on an ongoing basis, monitor implementation of and compliance with these principles. It shall be a fundamental principle with Travel Cashier Ltd that any Personal Data shall be processed fairly, sensitively, respectfully and in accordance with this Policy and applicable local law.

1) Notice: Travel Cashier Ltd will inform individuals about the purpose for which it collects Personal Data, how to contact Travel Cashier Ltd with inquiries or complaints, and the administrative process by which the complaints will be resolved. Where appropriate, Travel Cashier Ltd will communicate the types of third parties to which Travel Cashier Ltd discloses Personal Data, and the choices, procedures and means Money Messenger Ltd offers for limiting use and disclosure of personal information will also be provided.

2) Choice: Subject to applicable local law and Travel Cashier Ltd policies, general procedures and business requirements Travel Cashier Ltd will ensure that the rights of Data Subjects, about whom Personal Data is held, can be fully exercised. This includes the right of an individual to choose how their Personal Data provided is used, whether the use of such data is incompatible with the original purpose or authorizations, or is disclosed to third parties, subject to laws requiring disclosure and consent.

3) Onward Transfer: Travel Cashier Ltd will ensure that all transfers of Personal Data, whether within or outside of the Travel Cashier Ltd group, are protected by suitable safeguards and in accordance with applicable local law. Further, unless required by court or another legal mandate, or except as discussed below, Personal Data will only be transferred outside of Travel Cashier Ltd if the receiving party has entered into a Data Protection Agreement with Travel Cashier Ltd or comparable safeguards are in place. Where Personal Data is transferred outside of Travel Cashier Ltd, Travel Cashier Ltd will ensure that any such transfer protects the legitimate interests of Data Subjects in line with this Policy and applicable local law.

4) Security: Travel Cashier Ltd is committed to protecting Personal Data against unauthorized use or disclosure. To ensure the appropriate use of Personal Data, and prevent unauthorized access to such Personal Data, as well as prevent loss, alteration or destruction of Personal Data. In adherence with Data Protection and Privacy laws worldwide and internal Travel Cashier Ltd policies, Travel Cashier Ltd will address security at all appropriate technology infrastructure points.

5) Data Integrity: Travel Cashier Ltd will collect and process appropriate Personal Data only to the extent that there is a Business Need for Personal Data, to fulfill operational needs, and/or to comply with legal requirements, including those legal requirements of the countries in which the Personal Data was collected, as applicable. Travel Cashier Ltd will take reasonable steps to ensure that all Personal Data is relevant, accurate, complete, current, and reliable for its intended use. All Data Subjects have a responsibility to assist Travel Cashier Ltd in this effort.

6) Data Retention: Travel Cashier Ltd will not keep Personal Data for longer than is necessary for the purpose or purposes, for which it was intended, or as required by contractual agreement, by law or regulation, by other Travel Cashier Ltd policies or, where applicable, for the appropriate statute of limitations period.

7) Access: Upon request, Travel Cashier Ltd will provide individuals with access to their Personal Data and, when appropriate, allow the individuals to request that their Personal Data be corrected or updated by Travel Cashier Ltd, as required by law or Travel Cashier Ltd policies.

8) Enforcement & Oversight: Travel Cashier Ltd will address complaints or disputes regarding Personal Data promptly, in an orderly fashion and courteously. Travel Cashier Ltd will provide or, where appropriate, endeavour to provide notification to Data Subjects about how to file a complaint or inquiry and the administrative process to follow. Travel Cashier Ltd will perform a self-assessment on a regular basis to verify that this Policy is communicated, prominently displayed, implemented, and accessible. Travel Cashier Ltd will cooperate with the relevant Data Protection Authorities in the investigation and resolution of complaints relating to this Policy. Travel Cashier Ltd will seek, in a timely manner as practicable, to comply in good faith with the advice of these authorities

9) Training & Audit: Travel Cashier Ltd will provide appropriate training to all relevant staff handling and dealing with the Processing of Personal Data so that any such processing will be carried out in accordance with this Policy and applicable law. Travel Cashier Ltd will further ensure that Data Protection and Privacy is subject to periodic audit.

Transferring Your Data Outside The "EEA"

Travel Cashier Ltd does not transfer your data outside of the EEA.

If at some future time, if we require to transfer your data outside the European Economic Area (the "EEA"), the following principles shall apply:

1. Some of those countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection.
2. Other countries do not have the same level of legal protection as countries in the EEA, and we do transfer your data to a non EEA country, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, ensuring that the organisation receiving the data is registered with the EU-US Privacy Shield (in the case of transfers to the USA), or that we use the EU's model contractual clauses.

Covered Entities

Travel Cashier Ltd entities and all non-Travel Cashier Ltd entities (e.g., agents, contractors, outsource service providers and processors) accessing or processing Personal Data are required to comply with this Policy with respect to such Personal Data.

Responsibilities

The Data Officer is primarily responsible for adopting, implementing, and maintaining this Policy.

The responsibility for the implementation of the Policy lies with every employee and manager, whether the Personal Data is in the form of manual records, computer data or arises from communication with employees and Data Subjects both online (electronic) or off line (manual records). Implementation requirements will include the development of notice and consent forms to provide to managers and Data Subjects where required by applicable laws.

Employees, agents, contractors and their employees are individually responsible for providing/maintaining accurate information and for protecting the personal information that Travel Cashier Ltd has about any individual in support of the implementation of this Policy. Employees who violate this Policy or applicable legal requirements are subject to discipline, up to and including termination of employment, dependent on the severity of the violation. Agents or contractors or their employees who violate this Policy or applicable legal requirements are subject to termination and/or other contractual penalties. Employees, agents and contractors should also be aware that if they knowingly or recklessly obtain or divulge Personal Data without Travel Cashier Ltd consent, they may be committing a criminal offence.

Data Privacy Investigation & Dispute Resolution

The data privacy officer will address any complaints or disputes regarding Personal Data promptly and courteously and will follow all applicable laws to respond to the complaint. This includes inquiries from Data Subjects, employee councils, management sponsors, or regulatory authorities.

A responsible person designated by management will handle investigations regarding non-compliance with this Policy. All investigations will be handled under the legal requirements of the geographic area where the investigation is taking place.

Access To Personal Data

The Data Officer is responsible for maintaining and safeguarding Personal Data, and for ensuring that access to such Personal Data is restricted to persons who have a job-related "need to know" or who have documented access rights. Covered entities may have access to Personal Data on a business related need to know for purposes generally compatible with the collection of the Personal Data.

Data Subjects may review the contents of any files as requested pursuant to the access principles detailed above and subject to other Travel Cashier Ltd policies. If a data subject requests for the data that Travel Cashier Ltd Ltd holds on the consumer, the ID of the data subject will be requested and the data subject will be requested to provide this in writing, this will be reviewed by the data privacy officer. The consumer may also request this information by calling the office on 0203 3340 9757. The requested information will be provided within 30 days. For each request, a decision will be taken whether the data can be shared and if not, a reason will be provided to the consumer. Travel Cashier Ltd. Data Subject may request a copy of documents, but under no circumstances will an individual be allowed to remove any documents from the file or be allowed to remove the original file from Travel Cashier Ltd. Certain confidential files, such as investigative files, will not be accessible to Data Subjects.

Data Breaches

The UK GDPR imposes an obligation on all organizations to report certain personal data breaches to the relevant supervisory authority. This report must be made within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk to the rights and freedoms of data subjects, those data subjects shall also be informed without undue delay.

If it is suspected that the personal data of a data subject may have been compromised, the Data Privacy Officer(DPO) shall take immediate action. The DPO will arrange to contact the affected data subjects and will file a report with the ICO. A record will be maintained of any data breaches or reports of potential breaches.

Verification Of Employment

Regarding any requests for information concerning a Travel Cashier Ltd employee's status which may be received from non- Travel Cashier Ltd entities, only members of the senior management team are authorized to release any information and this will be restricted to confirmation of current employment including the employee's name, the most recent job title and the dates of Travel Cashier Ltd employment. Additional information will not be provided without the employee's authorization.

Cookies Policy

What Are Cookies?

Cookies are small files containing pieces of information, typically comprised of letters and numbers, that are stored on your computer or device when you visit a website. These cookies can be sent back to the website on subsequent visits. This process is crucial for the website's functionality, allowing it to remember important information across different pages and sessions.

Purpose of Cookies

Cookies serve a variety of purposes to enhance your website experience, including:

1. Navigation: Making it easier for you to move between pages seamlessly.
2. Preferences: Remembering your preferences and settings.
3. User Experience: Improving your overall interaction with the site.
4. Advertising: Making online advertisements more relevant to you and your interests.

Types of Cookies

1. Session Cookies: These cookies are temporary and are deleted once you close your browser. They are used during your current visit to remember your actions and preferences.
2. Permanent Cookies: These cookies remain on your device for a specified period or until you delete them. They remember your preferences and actions for future visits.

How We Use Cookies

Travel Cashier Ltd uses cookies to gather information about how visitors interact with our website. This includes data such as:

1. IP addresses
2. Connection speeds
3. Operating system details
4. Pages viewed during each session
5. Duration spent on specific pages

This information helps us understand website usage patterns, the number of visitors, and areas for improvement, ultimately enhancing the experience for all users.

Personal Data and Cookies

Through our use of cookies, we may obtain personal data about you. However, Travel Cashier Ltd does not attempt to personally identify visitors based solely on their IP addresses.

Managing Cookies — Non-Essential Cookies

You have control over non-essential cookies through our Cookies Management Tool. Upon your initial visit to our website, non-essential cookies are deactivated and remain so until you enable them.

1. Blocking Non-Essential Cookies: You can block non-essential cookies at any time by choosing and storing your preferences through our Cookies Management Tool.

Essential Cookies

Essential cookies are necessary for the website to function properly. While you can disable all cookies, including essential ones, by adjusting your browser settings, doing so may affect your ability to access all or parts of our site.

Disabling Cookies

1. Browser Settings: You can disable all cookies by activating the setting on your browser that allows you to refuse the setting of all or certain cookies.
2. Impact on Access: If you block essential cookies, you might not be able to access certain features or portions of our site.

Conclusion

Cookies play a vital role in enhancing your experience on Travel Cashier Ltd's website. We use cookies to understand and improve how our site is used, ensuring a better experience for all visitors. You have the ability to manage your cookie preferences and enhance your interaction with our site.

To opt out of being tracked by Google Analytics across all websites visit

http://tools.google.com/dlpage/gaoptout

Use Of Universal Analytics (Google)

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• _gali
• _gat_ UA 112356073-1
• _gid

Purpose: These cookies collect information about how visitors use our website. We use the information to compile reports and to make improvements. The cookies collect information in an anonymous form, including where visitors have come to the website from and the pages they visited.

Contacting Us

If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at [email protected]

Changes To Policy

Travel Cashier may from time to time amend this Policy to reflect changes in any applicable legislation. Travel Cashier will notify Data Subjects of such amendments as soon as reasonably practicable.