Worldwide Privacy Notice

Welcome to TMU Management!

Last Updated: January 05, 2023 

Privacy and online safety are important to TMU Management (“TMU”). We offer a software platform and services for analysing and declaring risk to insurers to protect either Travel Merchants and/or Service Providers (“Businesses”). We collect data about businesses and their customers (“Data”) when they use the platform, the services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data. 

In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our 
websites, a user of one or more of our Services (“User” or “Business”), or a customer of a 
User. We will do our best to clarify who we are referring to at 
various points in the policy. This policy does not apply to third-party websites, products, 
or services even if they link to our Services, and You should consider the privacy 
practices of those third parties carefully. If You disagree with the practices described in 
this policy, you should (a) take the necessary steps to remove cookies from Your 
computer after leaving our website, and (b) discontinue Your use of our Services. 

1.Overview

The Data we collect depends on how our Services are used. Sometimes we receive 
Data directly, such as when a TMU contract is created, test transactions 
are submitted through our website, the TMU form is used, or we receive an 
email. Other times, we get Data by recording interactions with our Services by, for 
example, using technologies like cookies and web beacons. We also get Data from third 
parties, like our financial partners or identity verification services. 

The collection and use of data from a variety of sources is essential to our ability to 
provide our Services – and to help keep the Services safe. Data is critical in helping us 
to increase the safety of your financial protection, and reduce the risk of fraud, money 
laundering and other harmful activity.

2. Data We Collect

a. Personal Data. We call Data that identifies, or that could reasonably be used to identify,You as an individual as “Personal Data”. We collect Personal Data in different
ways. For example, we collect Personal Data when a business applies for a TMU administered Insurance Policy, a customer makes payments or conducts transactions through a Business’s website or application, a person responds to TMU’s emails or 
surveys. We also receive Personal Data from other sources, such as our partners, 
financial service providers, identity verification services, and publicly available sources. 
Personal Data does not include Data that has been aggregated or made anonymous 
such that it can no longer be reasonably associated with a specific person.

The personal Data that we may collect includes: 

Contact details, such as name, postal address, telephone number, email address; 

Financial and transaction Data, such as credit or debit card number, and bank              account information; and other Personal Data, such as date of birth, SSN or EIN. 

b. TMU ‘Customer’, also referred to as ‘`Customer’.

TMU Processes Business data differently to Customer personal data.  Customer 
data is kept securely and separated from Business data for the protection of data 
subject(s).

c. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that 
implement our Services, and the use of our Services generally. Other Data that we may 
collect include: 

Browser and device data, such as IP address, device type, operating system and 
Internet browser type, screen resolution, operating system name and version, device 
manufacturer and model, language, plug-ins, add-ons and the version of the Services 
You are using; 

Transaction data, such as purchases, purchase amount, date of purchase, and payment 
method; 

Cookie and tracking technology data, such as time spent on the Services, pages visited, 
language preferences, and other anonymous traffic data; and 

Company data, such as a company’s legal structure, product and service offerings, 
jurisdiction and company records.

3. How We Use Data

a. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users,
Customers, and TMU; and (iv) promote, analyse and improve our products, systems, and tools. Examples of how we may use Personal Data include: 

To verify an identity for compliance purposes; 

To evaluate an application to use our Services; 

To conduct manual or systematic monitoring for fraud and other harmful activity; 

To respond to inquiries, send service notices and provide customer support; 

To make declarations to our insurers for the purposes of providing our Services; 

For audits, regulatory purposes, and compliance with industry standards; 

To develop new products; 

To send marketing communications; 

To improve or modify our Services; and 

To conduct aggregate analysis and develop business intelligence that enable us to 
operate, protect, make informed decisions, and report on the performance of, our 
business.

b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as 
Personal Data under this privacy policy.

4. How We Disclose Data

TMU does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:

a. To TMU Affiliates. We share Data with our other entities worldwide that we control, are controlled by us, or are under our common control, to provide our Services. TMU Management Ltd (UK) is the party responsible for overall management and use of the Data by these affiliated parties;

b. To TMU Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing
(i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, 
information technology and related infrastructure, customer service, Insurers, Trustees & 
Payments Houses.

c. To Our Users. We share Data with Users (such as Businesses and application providers) as necessary to provide the Services. For example, we share Data with Members about purchases made by TMU Customers through the online TMU dashboard.

d. To Authorised Third Parties. We share data with parties directly authorized by a User to receive Data, such as when a User authorizes a third-party application provider to access the Business’s Affiliate/Agents Product. The use of Data by an authorized third party is subject to the third party’s privacy policy;

e. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and

f. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.

5. Security.

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage 
system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.

6. Choice and Access.

You have choices regarding our use and disclosure of Your Personal Data:

a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out via
the unsubscribe link included in such emails. We will try to comply with Your request(s) 
as soon as reasonably practicable.

b. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.

c. How you can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, you may do so, by signing into your Dashboard if you are a member, or if you are a traveller, by 
contacting us. 

If emailing us Your request, please make clear in the email what Personal Data you would like to have changed. For your protection, we may only implement requests with respect to the Personal Data associated with the email address that You use to send us Your request, and we may need to verify Your identity before implementing 
Your request. We will try to comply with Your request as soon as reasonably practicable.

7. Retention Period.

We will retain Personal Data for the period necessary to fulfil the purposes outlined in 
this Privacy Policy unless a longer retention period is required or permitted by law. 
Please note that we have a variety of obligations to retain the Data that You provide to us, including to ensure that transactions can be appropriately processed, settled, 
refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if You end your TMU Contract, we will retain certain Data to meet our obligations. There may also be residual Data that will remain 
within our databases and other records, which will not be removed.

8.Use of Services by Minors.

The Services are not directed to individuals under the age of thirteen (13), and we 
request that they not provide Personal Data through the Services.

9. Jurisdiction and Cross-Border Transfer.

Our services are global, and Data (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Data to countries outside of Your country of residence, 
which may have data protection rules that are different from those of Your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that Your Data remains protected to the standards 
described in this privacy policy. 

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Your Personal Data.

10.Privacy Shield Certification.

If You are located in the EEA or Switzerland, we comply with applicable laws to provide 
an adequate level of data protection for the transfer of Personal Data. TMU is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.

11. TMU as a Data Processor.

We may collect, use and disclose certain Personal Data about Customers when acting 
as the Business’s service provider. Our Businesses are responsible for making sure that 
the Customer’s privacy rights are respected, including ensuring appropriate disclosures 
about third party data collection and use. To the extent that we are acting as a User’s 
data processor, we will process Personal Data in accordance with the terms of our 
agreement with the User and the User’s lawful instructions.

12. Updates to this Privacy Policy and Notifications.

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy 
Policy indicates when this Privacy Policy was last revised. Any changes are effective 
when we post the revised Privacy Policy on the Services. 

We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You through your TMU Dashboard, email address and/or the physical address listed in Your TMU account. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided you with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

01780 908135


TMU Management Limited
Suncrest, Throcking Lane, Buntingford, Hertfordshire SG9 9RP England 

Attention: TMU Management Limited 

For EU individuals: The entity that provides Services in Europe is TMU Management 
Limited (as stated above). 

Sensitive Information. Because email communications are not always secure, please do 
not include credit card or other sensitive Data (such as racial or ethnic origin, political 
opinions, religion, health, or the like) in Your emails to us.