L & P Phileas Fogg Travel Guides Ltd ("we" or "us") is committed to protecting and respecting your privacy.
1. SCOPE OF POLICY
1.1 This policy together with the General Terms of Service and our Business Terms of Service and our Business Terms (as applicable) apply to your use of:
a) our website at phileas.guide (the "Site") including, without limitation, the Dashboard available to Dashboard Users pursuant to the Business Terms;
b) the Phileas Guides Mobile Apps ("Apps") once you have downloaded a copy of the App onto your mobile telephone or handheld device ("Device"); and
c) any of the services accessible through the App or the Site (the "Services").
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.
Controller
We are the data controller responsible for your personal data.
Data Protection Officer
We have appointed a data protection officer ("DPO"). Our DPO has a number of important responsibilities including:
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO via in-App support.
Complaints
You have the right to make a complaint at any time. We would appreciate the chance to deal with your concerns so please contact us in the first instance.
So that we're clear and there's no misunderstanding about how we handle your personal data, we will:
Always keep your data safe and private.
Never sell your data.
Allow you to manage and review your marketing choices at any time.
2. COOKIES
2.1 We use cookies to distinguish you from other users of the App or the Site. This helps us to provide you with a good experience when you use the App or browse our Site and also allows us to improve the App and our Site.
3. INFORMATION WE COLLECT ABOUT YOU
3.1 We will collect and process the following data about you:
a) Information you give us "Submitted Information": This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site, participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
b) Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
(i) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting "Device Information";
(ii) information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
(iii) transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
(iv) information stored on your Device, including if you allow Phileas Payments access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically recollect this information in order to stay up-to-date;
(v) details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
c) Location Information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in the UK but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the Phileas Payments App within your device settings "Location Information".
d) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Phileas Payments Services like credit), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions. Please see the 'Disclosure of your Information' section for more information.
4. USES MADE OF THE INFORMATION
4.1 Below is a summary of the key types of data that we make use of as part of the Phileas Payments Services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:
(a) Submitted Information: We will use this information:
to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Bank Transfers, Electronic Money Exchanges, ATM Withdrawals and Card Purchases and to provide you with the information, products and services that you request from us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
to notify you about changes to our service;
(b) Device Information: We will use this information:
to administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Site and the App to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our Site and the App safe and secure;
to make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them;
to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
to comply with our regulatory obligations.
4.3 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4.4 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in Paris). In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
What do we mean when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing Phileas to enable us to provide to you the Phileas Guides Services and offer the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
5. MARKETING
5.1 We want to make it crystal clear how we use your data for marketing purposes and how you can 'opt-out' from receiving any marketing communications from us whenever you want.
5.2 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
6. YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via the in-App chat function.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via the in-App chat function.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Phileas Payments Services). In this case, we may have to cancel your use of the Phileas Payments Services but we will notify you if this is the case at th
e time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Phileas Payments Services to you. We will advise you if this is the case at the time you withdraw your consent.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Phileas Payments Services). In this case, we may have to cancel your use of the Phileas Payments Services but we will notify you if this is the case at the time.
7. CHANGES TO PRIVACY POLICY
7.1 Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail and/or when you next start the App or log onto the Site. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
8. CONTACT
8.1 All questions relating to data and your privacy are welcomed and should be addressed to our support team. If you have any questions, comments or requests regarding this privacy policy then please:
Contact Phileas support via our in-App contact function.