Privacy Policy

1. Who We Are (Data Controller)

Travel Money, Inc., is the data controller responsible for processing your personal data in connection with the operation of the Travel Money application and the provision of our services.

Our contact details are available in the Legal Notice on our website.

We process personal data in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation – "GDPR")
• French Act No. 78-17 of 6 January 1978 on data processing, data files, and individual liberties, as amended
• Any other applicable data protection laws (together, the "Data Protection Laws").

2. Scope of This Policy

This Privacy Policy applies to all Travel Money products and platforms, including but not limited to:

• Mobile applications
• Web applications
• Websites
• Browser extensions
• POS and marketplace platforms
• Any other platform through which Travel Money provides its services

(collectively, the "Application").

3. Services Overview

Travel Money enables users to benefit from value added tax ("VAT") exemptions or refunds on eligible goods purchased in participating countries (the "Tax Exemption").

To provide these services (the "Services"), Travel Money:

• Collects required information
• Performs administrative and regulatory formalities
• Interacts with customs and tax authorities
• Processes VAT refund claims and payments

All services are fully digital. Interactions occur through the Application, website, email, or customer service representatives. To access the Services, you must create and maintain an account.

4. Personal Data We Collect

4.1 Data You Provide When Creating an Account

When registering, we may collect and use the following personally identifiable information directly from you:

Contact and Identity Information

• First and last name
• Postal address
• Phone number
• Email address
• Date of birth
• Social media or webchat display name

Account Information

• Username and password
• Security questions and authentication data

Payment Information

• Bank account details (e.g., IBAN)
• Electronic wallet identifiers

Credit card details, if applicable, are collected and processed exclusively by our payment service providers. Travel Money does not store or control credit card data.

Travel and Eligibility Information

• Duration of your stay in the European Union

Identity Verification Data

• Copy or image of passport or national ID
• Photographs and biometric data (facial verification)
• Identity verification results and reports
• Data processed by third-party identity verification providers

Identity details are collected and processed by our verification providers. Travel Money does not store or control identity verification data.

Device and Location Data

• Real-time device location (only if you explicitly allow it)

Certain information is mandatory. If you do not provide required data, we may be unable to provide the Services or comply with legal obligations.

4.2 Data Collected When You Use the Services

When providing the Services, we may process:

• Transaction and order details
• VAT refund forms and receipts
• Export documentation, customs clearance, proof of delivery, waybill, resale invoices
• Payment history and saved payment methods
• Identity verification records
• Profile and account settings
• Location data relevant to tax and customs requirements
• Communications with customer support
• Any information you voluntarily provide
• Usage and interaction data related to the Application

Usage analytics may be collected through third-party tools (e.g., PostHog).

4.3 Technical and Usage Data

When you access or use the Application, we may automatically collect:

• Log files and timestamps
• IP address and device identifiers
• Browser and device type
• Crash reports and performance data
• Security and troubleshooting data

This information helps ensure platform security, reliability, and performance.

5. How We Collect and Share Personal Data

5.1 Collection

We collect personal data:

• Directly from you
• Automatically through your use of the Application
• Through authorized third-party service providers

5.2 Service Providers and Third Parties

We may share personal data with trusted third-party service providers ("Suppliers") who act on our behalf, including:

• Payment and banking providers
• Cloud infrastructure and hosting providers
• Identity verification services
• Customer support platforms
• Data analytics providers
• Legal, accounting, and professional advisors
• Insurance providers
• Marketing and communications partners

We only share data that is necessary for the relevant service and require contractual commitments to confidentiality and data security.

5.3 Legal and Business Disclosures

We may disclose personal data:

• To customs, tax, and administrative authorities as required to provide VAT refund services
• To regulators, courts, or law enforcement when legally required
• In connection with a merger, acquisition, restructuring, or sale of assets
• To protect our legal rights or prevent fraud or unlawful activity

Where legally permitted, we will notify you of disclosure requests.

6. Legal Bases for Processing

We process personal data based on one or more of the following legal grounds:

• Contractual necessity: to provide the Services
• Legal obligation: compliance with tax, customs, and regulatory requirements
• Legitimate interests, including:
  • Fraud prevention and security
  • Improving our Application and Services
  • Business operations and analytics
• Consent, where required (e.g., marketing communications)

When relying on legitimate interests, we ensure that such processing does not override your fundamental rights and freedoms.

7. International Data Transfers

Your personal data may be transferred outside the European Union. Where this occurs, we implement appropriate safeguards in accordance with GDPR and Data Protection Laws, including standard contractual clauses or equivalent mechanisms.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against loss, misuse, unauthorized access, disclosure, or alteration.

Access to personal data is limited to authorized personnel and service providers subject to confidentiality obligations.

9. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with legal obligations.

• Purchase orders: 7 years from payment date
• VAT refund records and receipts: 7 years from payment date
• Rejected or disputed claims: up to 10 years for fraud prevention
• General account data: for the duration of your relationship with us, plus applicable legal retention periods

Where deletion is not technically possible, we restrict further processing.

10. Your Rights

Under Data Protection Laws, you have the right to:

• Access your personal data
• Rectify inaccurate or incomplete data
• Object to processing based on legitimate interests
• Withdraw consent at any time
• Restrict processing
• Request erasure (where applicable)
• Data portability
• Challenge automated decision-making
• Lodge a complaint with a data protection authority

You may exercise your rights by contacting us at: support@travelmoney.app

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on our website and/or notified by email. Updates take effect 14 days after publication unless otherwise required by law.

If you do not agree with an updated policy, you should stop using the Services.

12. Contact

For any questions, requests, or complaints regarding this Privacy Policy or the processing of your personal data, please contact:

Email: support@travelmoney.app

Address: 14 Rue Charles V 75004 Paris