Travelex Currency Exchange (China) Limited Privacy Notice

Travelex Foreign Currency Exchange (China) Co., Ltd. Privacy Policy

1.   Introduction

Your privacy and your rights are important to us. This privacy policy explains what information we collect about you and how we use it. By ‘we’ or ‘us’ or ‘our’ we mean Travelex Foreign Exchange (China) Co., Ltd.

If you subscribe to or have purchased, Travelex products and services (in store or online), you visit our websites or you download and use our mobile apps or services we provide within mobile device wallets or other third-party applications and platforms, this Privacy Notice will apply. Please read and understand this policy carefully before using our products or services.

• Travelex recognises the importance of safeguarding the personal information (“information”) of its customers using the Travelex Services. This Privacy Policy (the “Policy”) sets out the basis on which any of your information will be collected, stored, and used by us, and reflects Travelex's commitment to maintain the confidentiality and security of your information and to provide its customers with the best possible service.
• This Policy describes how your information is used by us when:
• you use this website (the “Website”), any of our mobile software applications (Apps) or platforms (together the “Sites”).
• you use services we provide within mobile device wallets or third-party applications and platforms, such as WeChat Mini Programmes.
• you obtain services from our bureaux de change stores, by either using our online ordering interface or by walking into one of our stores.
• you call the customer services telephone lines or when you interact with us using other channels including by email, live chat, SMS, or social media platforms (e.g. WeChat or other platforms).
• you purchase or use Travelex-branded products or products we provide under the branding of our partners. These services and products are collectively referred to in this Notice as “Travelex Services”. Dependant on how the services are provided to you, the partner’s Privacy Notice may also apply.

2.   What Information we collect

Travelex collects, stores, processes, and discloses (collectively "uses") your information in a manner consistent with laws of the People's Republic of China, including but not limited to the Personal Information Protection Law of the People's Republic of China, the Data Security Law and the Cybersecurity Law (collectively, the "Data Protection Law").

We collect and process your information in the following ways:

• Information you give us
• You give us information about yourself when you purchase or use Travelex Services, or communicate with us (whether in writing, by phone, via social media or by any other means), or enter into any of our competitions, promotions or surveys. Where we request information from you, we will collect your information in the relevant forms or pages we use, including when you set up an account with us or when you register for loyalty schemes offered by us. You can choose to provide additional information to us when you contact us or otherwise interact with us.
• The registration details that you provide when you register a particular product sometimes include a unique ID for that product, mobile phone number, and your email address. If you register your product, you may also have a unique password which enables you to access your account.
• If you purchase any Travelex Services, we will collect information from you that will enable us to complete your transaction and fulfil our legal obligations Such information can include your name, date of birth,  ID type, ID number, ID expiry date, nationality, the form(s) of identification you provide (e.g. passport or residence card, copies of your ID documentation and the information contained within those documents, contact details (e.g. telephone number, landline telephone number), credit or debit card information, other payment details, such as your bank account information, as required by us in order to complete your transaction and provide your payment choices If you do not provide the information we require to process a transaction in compliance with local laws and regulations, we may not proceed with your order.

• Information we collect automatically

Travelex also may collect certain information about you by automated means, such as cookies and web beacons, whenever you visit our Sites or when you use the Travelex Services and how you use them. More information can be found in IP Address and Cookies section below.

We use the information we collect automatically:

• to administer our Sites for internal operations including troubleshooting purposes.
• to ensure that content from our Sites is presented in the most effective manner for you and your devices;
• as part of our effort to keep our Sites safe and secure;
• to establish communication that allows you to give feedback and/or reviews on Travelex services.
• When we collect CCTV images of you from equipment in place when you visit our premises such as at our bureaux de change stores, we will do so for the prevention and detection of crime and public safety.

• Information we receive from third parties 

We also receive information from third parties (including publicly available information). This information includes: 

• Non-personal information used to supplement existing information, such as demographics and affluence metrics (e.g., social-demographic groupings through matching postcode information).
• Information about you from other sources with whom Travelex work closely to provide the Travelex Services to you (including Travelex partners, third-party payment and delivery service providers, advertising networks, analytics providers, identity verification services, credit reference agencies, fraud prevention services and social media platforms).

3.   How we use the information we collect

The information we hold on you will be used in a number of ways. This is generally to provide you with the services that you request from us, to keep you informed and to improve your customer experience and the quality of the Travelex Services. We use your information for the following purposes: 

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

• collecting payment, processing, and fulfilling your order and otherwise providing you with the information and Travelex Services you request from us; 
• providing you with any alerts, in-app messages or other messages, a
• when we partner with other organisations to provide a particular Travelex Service (these partners will be identified to you at the time of the provision of the relevant Travelex Service e.g., when you visit the partner site, platform or bureaux de change); 
• providing you with service messages, including messages notifying you about changes to Travelex Services or changes to our terms, conditions, and policies; 
• enforcing any contract entered into between you and us for the provision of Travelex Services. 

Where we have your consent 

• when you are using a mobile device (such as and not limited to mobile phones, tablets, or other wearable devices), we may use your precise geo-location to provide you with location-based services and provide you with targeted advertisements. You can control your geo-location settings within the app settings or your mobile device settings; 
• enabling us and third-party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or any other relevant information; 

Where we have a legitimate interest 

• data analysis and research to allow us to derive insight and to help make the Travelex Services personalised and relevant, as well as to develop our business processes and Travelex Services. 
• sharing any loyalty card number, you have provided to us, with the providers of the loyalty scheme, in order for you to receive points, where you have already consented to this with the loyalty scheme provider; 

Customer Surveys 

• Travelex may invite you to review any service and/or products you receive from us in order to collect your feedback and improve our services and products (the “purpose”). Travelex may also use such reviews for advertising and promotional material. 

Where we have a legal obligation 

• complying with our legal and regulatory obligations (including Foreign Exchange Control Regulations of the PRC, fraud prevention, anti-money laundering).

How we use your information in Travelex Mini programmes

• Account Registration

If you want to use the products/services on the Travelex Mini Programmes available on WeChat   you first need to register a Travelex account to become a member of the Travelex Mini Programme . When registering, you must at least provide a mobile phone number (for receiving SMS verification codes) and create a Travelex Mini Programme account. If you refuse to provide your mobile phone number, you may not be able to create an account on the Travelex Platform and use the products/services on the Travelex Platform.

• Account Login

If you choose to log in to the Travelex Mini Programme through a third-party account (including WeChat), after you agree to this policy, we will obtain the third-party account information (avatar, nickname and other personal information) that you authorize to share from the third party, and connect your third-party account to your Travelex Platform account, so that you can log in directly through the third-party account and use our services. We will use your personal information in accordance with the agreement with the third party and in compliance with relevant laws and regulations.

• We collect this information to help you confirm transactions, payment settlements, receive notifications, and help you query and manage order information, as well as provide customer service and after-sales service to you whenever needed. We may also use your order information to determine whether there are any abnormalities in your transactions to Travelex's statutory duties or obligations;
• Related to national security and national defense security;
• Related to public safety, public health, and major public interests;
• Related to criminal investigation, prosecution, trial, and execution of judgments;
• In an emergency, to protect the life, health, and property safety of you or other individuals;
• The personal information collected is the personal information that the subject of the personal information has disclosed to the public on his own or other personal information that has been legally disclosed;
• Your personal information is collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;
• Other circumstances stipulated by laws, regulations and national standards.

Please be aware that, in accordance with applicable laws, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, the use of such processed data does not require additional notification to you and your consent.

If we stop operating the Mini Programmes, we will promptly stop collecting your personal information. At the same time, we will continue to store, delete or anonymize the personal information we store in accordance with laws, regulations or regulatory requirements.

4.   Sensitive Information

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

We generally do not accept transactions from minors under the age of 16 and therefore do not collect or retain such sensitive information.

We will not collect and process your sensitive personal information unless it is necessary to process it for a specific, necessary and lawful purpose, and we have informed you of this necessity or obtained your separate consent. If laws and regulations provide that the processing of your sensitive personal information shall be permitted or otherwise restricted by any other relevant laws, the relevant provisions shall prevail.

5.   Disclosure of Personal Information

We will not disclose your personal information unless you have given us your consent.

Please understand that we may disclose your personal information without your consent in the following circumstances:

• Disclosure is required or authorised by law, for example, to disclose your personal information to government or regulatory authorities for purposes related to public health or safety, to prevent or detect illegal activities, or to protect public revenue.
• Criminal investigation, prosecution, trial and enforcement of judgments.
• to comply with anti-money laundering and sanctions provisions.
• you have made your personal data public; or
• We obtain your personal data from legitimate public sources, such as legitimate news reports or publicly available government information.

6.   International Transfers

The personal information we collect and generate in China will be processed and stored in China. 

If we need to transfer your personal data to another country/region, either to Travelex Group companies or third-party service providers overseas, we apply the same level of protection as would be necessary under the PIPL. We will comply with the notice and consent requirements under the PIPL. We also undertake to comply with any requirements or conditions for cross-border transfer of Personal Information that the state cyberspace authorities and other authorities/regulators may issue and will update this section as may be necessary.

7.   Information We Share

We will only share your information in the limited circumstances listed below to achieve the specified purposes. However, we will never sell your information.

Even in the case of sharing information with third parties, who act under Travelex's express instructions in accordance with this Policy and applicable laws; we ensure that your information is only used for the purposes described in this Policy.

Our business partners may include the following types of organisations:

• Payment gateways and payment service providers
• Identity verification providers
• Cloud and online security service providers
• Providers of telecommunications, webchat, and networking services

You may find the complete list of third party/partners which involves share of personal information in appendix one for more detail.  

We also disclose information about you to law enforcement authorities or other government officials, if we are required to do so by law or legal process, or when disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity such as financial crime. We have aggregated, non- personally identifiable information, which is to be used for segmentation, statistical modelling, general research, or trend analysis。

We may share your information with third parties in the following circumstances:

1. In the event of the sale or purchase of any new business or assets, we will disclose your information to the prospective seller or buyer of such business assets;
2. In the event of a third-party acquisition, the information in our possession, including your information, may be transferred in accordance with applicable laws. In this case, we will notify you by the most appropriate means;
3. In the event of any of the above, we will inform you of the name and contact information of the data recipient.

8.    Your Rights

You have certain rights (subject to certain conditions) in relation to your information in accordance with the law. These rights include the right to ask what information we have about you and to request that inaccurate information be corrected, missing information added or deleted. You also have the right to object to our processing of your data or to request that we process your information on a limited basis. If you wish to use your information for services with others, you can ask us to provide your data in a commonly used electronic format.

• The right to be informed. You have the right to clear, transparent and easy-to-understand information about how we use your information and your rights. That's why we want to provide you with the information in this Privacy Policy.
• Right of Access. You have the right to access your own information (if we are processing it), as well as certain other information (similar to the information provided in this Privacy Policy). so that you know and can check whether we are using your information in accordance with data protection laws.
• Right to rectification. If your information is inaccurate or incomplete, you have the right to request rectification. You may contact us to request that we correct inaccurate information records.
• Right to restriction of processing. You have the right to "block" or restrict further use of your information. When processing is restricted, we can still store your information but not use it further. We maintain a list of individuals who request to be "blocked" from further use of their information to ensure compliance with restrictions in the future.
• Right to withdraw consent. Even if you have given us your consent to the processing of your information, you still have the right to withdraw your consent at any time (the original consent is still lawful). You may withdraw your consent to the processing of your personal information at any time by contacting us.
• Right to delete. Under certain circumstances you may request us to delete your personal information via contacting us through the contact information in this Policy, However, please note when you ask us to delete your information, we may no longer be able to provide you with the corresponding services. We may not be able to immediately delete the corresponding information from the backup system due to applicable legal requirements or security technical reasons. However, we will securely store your personal information and isolate it from any further processing until the backup is updated and the information can be cleared or made anonymous. If you wish to access or correct your personal information, or to assert any of your other rights, you may contact us by email or phone. Please also understand that we may not be able to process your request from time to time due to record-keeping requirements or other restrictions imposed by laws and regulations.

We ensure that the information we hold about our customers is accurate, up-to-date and complete. We will respond to the customer's request for the above rights within 15 working days.

9.   Security

We take all reasonable steps to ensure that all information collected is treated securely and in accordance with this Privacy Policy. We meet legally regulated standards by taking appropriate technical and organisational measures, including regular review measures.

We have put in place a number of security measures to protect the information you provide to us through the Travelex website, applications, and platforms against unauthorised disclosure, use, alteration or destruction. However, when transmitting information over the Internet, please keep in mind that no transmission of information over the Internet can be guaranteed to be completely secure. Therefore, while we strive to protect your information, please note that we cannot guarantee the security of any information you transmit to us over the Internet.

As part of using our Sites, you are sometimes asked to set-up a username and password. You are responsible for maintaining the confidentiality of your username and password and are responsible for all activities that are carried out when logged using your name and password. You are responsible for ensuring the security of the passwords that you set. 

10.   IP addresses and cookies

We may collect information about your visits to the Site and your computer (including, if any, your IP address, operating system, and browser type) through the use of "cookies". Cookies are small pieces of information that your browser stores on your computer's hard drive. The information collected by "cookies" does not identify you personally. They help us to improve our website and make it possible for Travelex to recognise some of your preferences. When you revisit the website, Travelex's computer servers recognise the cookie and show us information about your previous visit.

Most browsers are initially configured to automatically accept cookies, however, you can refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. Please note that if your browser is not properly configured, or if you change your browser so that it cannot accept cookies, you may not be able to use this website. Unless you have adjusted your browser setting so that it refuses to accept cookies, our system will automatically issue cookies when you log in to the website.

11.   opt Out of Marketing, Promotion, or Related Activities

We may contact you by mail, telephone or email in order to provide you with services or to inform you about relevant products, promotions, newsletters, surveys and similar materials (which may be pushed and updated from time to time based on your preferences). If you do not wish to receive any such information, please let us know so that we can cancel your subscription or service or delete information about you. Please see the contacts section of this document for more details.

12.   Storage and Retention of Your Information

We will only retain your information for as long as it is necessary to use it as set out above or to comply with a legal obligation. Where you are a customer, this is usually at least for as long as you remain a customer, to be able to meet our legal and contractual obligations to you, and if necessary, to resolve any disputes. We will not keep more information than we need. 

Please note, however, that we retain some of your information after you stop using Travelex Services, for example, to comply with our legal obligations, for tax and accounting purposes, or to meet anti-money laundering obligations, or to fulfil our contractual obligations to you, and if necessary, to resolve disputes. We don't keep more information than we need.

When determining the relevant retention period, we will take into account the following factors:

• our contractual obligations and rights in relation to the information;
• legal obligations imposed by applicable law to retain data for a certain period of time (e.g., our obligations under current foreign exchange business regulation in China is to keep all electronic business record permanently) ;
• restrictions imposed by applicable law;
• (potential) disputes; and guidelines issued by relevant authorities or regulators.

Otherwise, we will securely delete your information once it is no longer needed.

13.   Links to Third Party Websites

Our website or platform may, from time to time, contain links to third-party websites or applications or platforms. If you click on a link to one of these third-party websites, please note that these websites have their own privacy policies and therefore we do not accept any responsibility or liability. Therefore, it is a good idea to review these policies before you submit any personal information to these websites.

14.   Changes to the Privacy Policy

We may modify the terms of this Privacy Policy at any time without notice. Any changes to the Privacy Policy will be posted on the Website. Please check back from time to time for updates. Your provision of personal information to us, or your use, access, or browsing of the Site after we make changes to the Terms, will be deemed to be acceptance of those changes.

This policy was last updated on 8^th Dec 2025.

15.   Contact Information

If you would like to have more information about how your personal information is collected, used, disclosed or stored, and if you would like to unsubscribe from promotional or marketing emails or correspondence, you may contact us at:

• E-mail: ChinaDPO@travelex.com.cn
• Mailing address: Attn: Travelex Currency Exchange (China) Co., Ltd. Data Protection Team Address: Room 603-604, 6th Floor, Building E2, No. 21, Lane 58, Pandong East Road, Qingpu District, Shanghai, China

Service hours: 9:00 a.m. to 5:30 p.m

We will respond to your request within 15 business days of receipt.

Appendix 1: List of Third-Party Service Providers for personal data sharing (Bilingual Version)