UAB „Travel Union (hereinafter – TU or “we”, “us”) is concerned about children’s privacy. The TU mobile application that we operate provide a forum for all family members, including children, from 7 years of old to 18 years of old, dispose of TU Card, to pay for things and learn how to use money. While we encourage children to participate appropriately in TU services, but their privacy is extremely important to us.
The document provides parents and/or with important information about privacy and data protection that you should take into account when deciding whether to allow your child to access TU services. Your child’s ability to have TU Account or TU Card requires your permission to collect, use child information as described in this document (including the Privacy Notice for Parents) and the TU Privacy Policy
Your parent will look after your opened TU Wallet and manage TU Card for you. Your parents will have put money on your TU Wallet and/or TU Card so you can use it to pay for things.
TU mission is to take the stress out of giving cash to children. The primary benefits for parents of the TU products are:
This Children’s Privacy Policy explains our information practices in connection with information provided by all children under the age of 18 whose parent’s consent we require for certain uses of their information (“Child” or “Children”) on TU Mobile App that link to this Children’s Privacy Policy.
Before you start using TU Wallet and/or TU Card, we need to stress out about how we use information about you (your data). Your parent will open your TU Wallet and/or TU Card for you and they can check how you use your account, what you’re spending your money on and how much money is in your account (so they know when to top it up), they can see your data. TU can also see your data because we need to use it to run your account. We do not want other people or companies to see your data if you do not want them to.
Our goal is to minimize the information gathered from and disseminated about Children while permitting them active participation in the trustworthy information.
The TU App are controlled and operated by us from Lithuania. Data controller - TU.
Children’s Privacy Policy explains how we collect, store and use the personal data you provide to us. We’ll keep it updated so that you can be confident when sharing your data with us that it will only be used in accordance with this policy. If you have any questions concerning your personal data and how we look after it or you would like to update how you would prefer to hear from us then please email dpo@travelunion.eu
Children can register (with certain limitations and permit of parent), explore TU Mobile App, and can use TU Card to pay for things, gain financial literacy skills while using TU Mobile App functionalities. TU collect information including the date, where you are and the amount you spend while providing only the limited personal information set out below:
Account set-up and Maintenance. If a Child wants to register to become a member of TU Mobile App, we require the Child to submit the following information:
We may use information collected from Children during the registration process and in TU Wallet and/or TU Card configuration in the following manner:
Use of anonymous information. If the information collected from a Child does not identify or allow contact with him or her or his or her device (including, for example, aggregated information), we may use and disclose it for any purpose, to the extent permitted by applicable law.
No advertisements! We do not display advertising based on information collected from Children.
No newsletters! Our email newsletters are for adults only – they are not designed for, or targeted at, Children. Children should not attempt to sign up for our email newsletters. We encourage parents to discuss with their Children the importance of not signing up to receive our email newsletters.
Persistent Identifiers. When client interact with the TU Mobile App, certain technical information may automatically be collected, to make TU Mobile App more interesting and useful, to track analytics, to keep them free of spam, and for various internal purposes related to our business. Examples of information that is automatically collected include: the type of computer operating system, the device’s IP address or mobile device identifier, the web browser, the frequency with which the user visits various parts of our TU Mobile App, and information regarding the online or mobile service provider — however, we do not collect any of this information from Children. Analytics and Personalization Cookies are turned off for logged-in children.
Personal data collected and processed by us may be used for the following key purposes:
We do not disclose to third parties any Children’s personal information that we collect other than as follows, consistent with applicable law: (a) with a parent’s permission, (b) as required by any applicable law, © to third-party service providers who help us operate or manage TU Mobile App, (d) as part of aggregated data shared with third-party service providers, our Board of Directors, funders and other partners, as described in the Privacy Policy, (e) to comply with legal process, (f) to respond to governmental requests, (g) to enforce our Terms of Service, (h) to protect our operations, (i) for assistance in fraud detection and prevention; (j) to protect the rights, privacy, safety or property your Child or others, (k) to permit us to pursue available remedies or limit the damages that we may sustain, and (l) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as a sale, merger, consolidation, reorganization, joint venture, assignment, or bankruptcy or similar proceedings.(m) to share your data with people who help us run our business (like lawyers and accountants who help us to make sure we’re following the law and doing things right). (n) to share your data with official people who keep an eye on what we do to make sure we are looking after you properly. There are laws that make us do this.
If parental consent is required in respect of our use of a Child’s personal information, when setting up an account and making registration in TU Mobile App, the Child must:
Deleting your Children’s information and their account.
If you are a parent, and we need your consent to certain processing of your Children’s personal information, if you:
TU will delete your Child’s Profile, and any parental contact information we may hold, on request.
Parents of Children can exercise these rights through our data protection officer, contacting by dpo@travelunion.eu
Accessing or changing your Children’s account and any personal information we have collected.
Parents may at any time:
by clicking on their Child’s “My Account” link, by contacting us at support@travelunion.eu, or by writing to us at the address provided below.
For your Child’s protection, we may need to verify your identity before implementing any request described in this Section E. We will try to comply with your request as soon as reasonably practicable.
If a parent has any questions or concerns about his or her Child’s use of the Sites, we encourage the parent to contact us at dpo@travelunion.eu
What do we mean by “Personal Data”? Under European data protection law, “Personal Data” refers to information about an identified or identifiable natural person. For European Children, references to “personal information” or “information” elsewhere in this Children’s Privacy Policy should be read as including reference to their Personal Data.
EU-specific rights. Under certain circumstances, Children may have certain rights – including those set out below:
How to exercise these rights? These rights can be exercised by using our TU Mobile App. There is no fee for this. We may need to ask for information in relation to any request to help us confirm the identity of the person making it and to speed up our response.
The right to complain. We would love to be able to resolve all questions, requests and complaints about Personal Data directly. However, if a Child or their parent feels we have not been able to satisfactorily resolve an issue, they may contact their local data protection supervisory authority. For the contact information of the Data Protection Authorities, please click https://vdai.lrv.lt/ .
What Personal Data do we use? The Personal Data that we use is set out in Section A of this Children’s Privacy Policy.
Our “Legal Bases” for using Personal Data. The GDPR requires us to have a “legal basis” for each way that we use Personal Data. Most commonly, we will rely on one of the following legal bases:
Where we need to perform a contract we are about to enter into or have entered into with a Child (“Contractual Necessity”).
Where it is necessary for our legitimate interests and the Child’s interests and fundamental rights do not override those interests (“Legitimate Interests”).
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have specific consent to carry out the processing for the Purpose in question (“Consent”), in these cases we would need to get a Child’s parent’s consent.
Purposes for Processing. We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use Children’s Personal Data:
Purpose limitation. We will only use Children’s Personal Data for the purposes for which we collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use Children’s Personal Data for an unrelated purpose, we will update this Privacy Policy. Please note that we may process Children’s Personal Data without their or their Parent’s knowledge or consent, in compliance with the above rules, where this is required or permitted by law (including the GDPR).
What happens when you do not provide necessary Personal Data or you withdraw consent? Where we need to process a Child’s Personal Data either to comply with law, or to perform the terms of a contract we have with them and they fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into. Similarly, if we rely on Consent to process Children’s Personal Data, they or their parent may withdraw that Consent, but if this happens, we may not be able to provide certain services or features.
International transfers. We are headquartered in the Lithuania. The Personal Data information that we collect from and about Children will be stored and processed in the EU and may not be stored and processed in other countries outside of Europe. However, it is our policy to ensure that adequate contractual or other safeguards are applied to Personal Data transferred outside of the European Union where required by European data protection law. If you have questions about the safeguards applied to Children’s Personal Data, you may contact us at dpo@travelunion.eu
Data security and retention. Our data security and retention practices are described in our general Privacy Policy – please see https://www.travelunion.eu/privacy.html
Personal Data from Third Party Sources. We do not collect any Personal Data about Children from any third parties or publicly-available sources, other than from their parents (where they choose to give it to us).
We need to keep your data while you have TU Wallet and/or Card.
We may need to keep your data for longer if the law says we have to. So even if you ask us to destroy your data, we may not be able to do that straight away.
If you close your TU Wallet, we’ll keep your data for up to ten years. We may need to keep it even longer if we need to use it in a court case because some person or company says that we have broken the law but we don’t think we have.
If you have any questions about your data, email us at dpo@travelunion.eu or support@travelunion.eu Your parent can also get in touch with us about your account.
If you are unhappy with how we use your data, or you have a complaint that you don’t think we have answered properly, you (or your parent or guardian) can contact your local data protection authority.