Last Updated: November 15th 2023

Privacy and online safety are important to Trust My Travel. We offer a software platform
and services for helping run a travel business so that it is secure and trusted by buyer
and seller. 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 “travel provider”), or a customer of a
User (“Customer” or “traveller”). 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 Trust My Travel account is created, test transactions
are submitted through our website, the Trust My Travel 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 online payments, 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 Trust My
Travel account, a Customer makes payments or conducts transactions through a Travel Provider’s website or application, a person responds to Trust My Travel’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. Trust My Travel ‘travel provider’ vs Trust My Travel ‘Customer’, also referred to as
‘Traveller’.

Trust My Travel Processes Travel Provider’s data differently to Traveller personal data. Traveller’s data is kept securely and seperated from the Travel Provider’s data for the protection of data

subject(s).

For information about how we handle historic data, notably before the imposition of the
General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on
data protection on May 25, 2018 – please contact us.

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 Trust My Travel; 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 process a payment using our ‘offline payment’ feature, communicate regarding a
payment, and provide related customer service;

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

Trust My Travel 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 Trust My Travel 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.
Trust My Travel Ltd (UK) is the party responsible for overall management and use of the
Data by these affiliated parties;

b. To Trust My Travel 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 travel provider’s and application
providers) as necessary to process payments or provide the Services. For example, we
share Data with travel provider’s about purchases made by Trust My Travel Customers through
the online Trust My Travel 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 travel provider’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 in to your Dashboard if you are a travel provider, 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 particular 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 Trust My Travel account, 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. Trust My Travel is
certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework.

11. Trust My Travel as a Data Processor.

We may collect, use and disclose certain Personal Data about Customers when acting
as the travel provider’s service provider. Our travel provider’s 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 Trust My Travel Dashboard, email address and/or the
physical address listed in Your Trust My Travel 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.

+44 1780 679 894

Trust My Travel Ltd
Unit 10, Tinwell Business Park,                                                                                                                                        Steadfold Lane,                                                                                                                                                            Stamford                                                                                                                                                                                  PE9 3UN 

Attention: Trust My Travel

For EU individuals: The entity that provides Services in Europe is Trust My Travel
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.