By providing personal information to us (or allowing another person to do so on your behalf), you agree that this Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Policy. If you do not agree with any part of this Policy, you must not provide your personal information to us and this may affect the services we can provide to you.
For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) we are a “data controller” for the processing of personal information you provide to us.
In this Policy, where we say “disclose”, this includes to transfer, share, send, or otherwise make available or accessible your personal information to another person or entity.
What is personal information?
Personal information is information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.
How do we collect personal information?
Where practical, we will collect personal information directly from you. Generally, this collection will occur when you deal with us either in person, by telephone, letter, facsimile, email or when you visit our website. We may collect personal information about you when you purchase or make enquiries about products and services, when you enter competitions, when you register for promotions, when you subscribe to receive marketing from us (e.g. e-newsletters) or when you request brochures or other information from us. We may also collect your personal information when you complete surveys or provide us with feedback.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. Where this occurs, we will assume you have consented to your personal information being collected by us and to us handling it in accordance with this Policy. You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent.
What personal information do we collect?
Generally, the type of personal information we collect about you is the information that is needed to respond to your queries about our products and services and/or provide requested products or services to you. For example, we may collect details such as your name, residential address, mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details and other details relevant to your order, receipt, or use of a product or service from us. When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback form you have sent to us. We also collect information that is required for use in the business activities of FCM Travel Solutions and our related entities, including for example, financial details necessary in order to process various transactions, and any other relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which is regarded as sensitive information. Sensitive information includes types of personal information such as your racial or ethnic origin, religious beliefs or affiliations, criminal record and health information. We will only collect sensitive information about you with your consent and where reasonably necessary for, or directly related to, one or more of our functions or activities. Where you provide sensitive information to us, you consent to us using that sensitive information for the purpose for which it was collected.
When we act as agent
When we book and otherwise arrange products and services for you, we usually do so as agent. This means that we usually collect personal information about you both for our internal purposes (e.g. to process the transaction requested by you), and on behalf of the parties for whom we act as agent, for their internal purposes (e.g. to provide the services you requested). Accordingly, the consent you provide under this Policy to the collection and use of personal information by us, applies equally to the parties whose products and services we sell. For example, if you purchase foreign exchange from us, then under this Policy you will have consented to your personal information being provided to FCM Travel Solutions India Pvt Ltd to enable your Currency Card to be activated.
Our company group acts as agent for or on behalf of many thousands of service providers, so it is not possible for us to set out in this Policy all of the service providers for whom we act nor exactly how each of these service providers will use your personal information. If you wish to contact us for further information, please refer to the “Feedback / Complaints / Contact” section below.
How do we use personal information?
Where you contact us in relation to products or services, the primary purpose for which we collect your personal information is generally to provide you with the products and services or information about such products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Policy.
By providing us, or otherwise allowing us to collect, your personal information, you consent to us using and disclosing your personal information for the purposes for which it was collected, and for related or ancillary purposes, such as any one or more of the following purposes:
identification of fraud or error;
regulatory reporting and compliance;
developing, improving and marketing our products and services and those of our related entities;
servicing our relationship with you by, among other things, providing updates on promotions and services we think may interest you;
involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you;
to facilitate your participation in loyalty programs;
to analyse trends in sales and travel destinations;
for marketing activities including but not limited to mail-outs, emails, e-newsletters, SMS notifications and telephone calls;
internal accounting and administration; and
other purposes as permitted or required by law (e.g. to prevent a threat to life, health or safety).
We will only send e-newsletters or other promotional materials to you if you have opted in to receive them. You can subscribe to receive e-newsletters and other promotional materials by following the relevant links on our website.
We are only allowed to store your personal information for as long as necessary having regard to the purpose for which it was collected or a related or ancillary purpose. We may therefore delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.
Is personal information disclosed to third parties?
Yes. You also consent to the personal information about you which we collect or receive being processed, transferred and/or disclosed by us in the following circumstances:
in each of the circumstances set out in the previous section “How do we use personal information?”;
as permitted or required by law;
to various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes;
to third party suppliers of IT based solutions that assist us in providing products and services to you;
to our related entities and brands (including companies based overseas);
to comply with our legal obligations and any applicable customs/immigration requirements relating to the products and services provided to you;
to comply with a request from a qualified government department if we are satisfied that they have the authority to make such request;
where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter;
to third parties who may involve you in market research for the purpose of servicing our relationship with you and improving the services we provide; and
to third parties for the purpose of analysing trends in sales and travel destinations.
Companies to whom personal information is disclosed which are registered in the United States may be required to provide information under the USA PATRIOT Act H.R. 3162.
Trans-Border data flows
We deal with many different service providers all over the world, so it is not possible for us to set out in this Policy all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please refer to the “Feedback / Complaints / Contact” section below.
Security of information
FCM Travel Solutions regularly reviews security and encryption technologies and will strive to protect your personal information as fully as we protect our own confidential information.
Access to and correction of personal information
Tracking Technologies / Cookies
If you reject cookies, you may still have access to our website, but your ability to use some areas of our website, such as contests or surveys, will be limited.
You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access athttps://tools.google.com/dlpage/gaoptout/.
Web Beacons / Gifs
3rd Party Tracking
Behavioural Targeting / Re-Targeting
Feedback / Complaints / Contact
Changes to our Policy