Privacy Policy

Privacy Notice

Last updated: 31 March 2026

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This privacy notice for WithU Travel Limited (doing business as TrvlWell) ("we", "us", or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Visit our website at

https://trvlwell.co

(or any website of ours that links to this privacy notice)

Download and use the TrvlWell app (the “App”), whether from the Apple App Store, the Google Play store or otherwise

Engage with us in other related ways, including any sales, marketing, enquiry or events

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If you have any questions or concerns, reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. For any further inquiries, please contact us at info@trvlwell.net.

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SUMMARY OF KEY POINTS

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This summary provides key points from our privacy notice. For more details on each topic, click the corresponding link below or refer to the Table of Contents.

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What personal information do we process?
When you visit our website, use our Services or otherwise interact with us, we may process personal information based on your interactions, choices, and the products and features you use.

Do we provide Services to minors?
We do not knowingly collect and process information relating to people aged under 18, athough we accept it may be possible for a user to upload data relating to minors as part of the use of our Services.

Do we process any sensitive (sometimes referred to a “special category”) personal information?
We may collect or be able to infer health information, such as what activities you do, and how often, as well as other types of sensitive information, when you use our services as well as when you upload documents, or other data, for the purposes of our services. Where we are able to identify you and connect you with that information it is considered sensitive personal information under certain laws. We will not collect such information without your consent, and you can withdraw your consent at any time.

Do we collect any information from third parties?
We do not generally collect any personal information from third parties, but we may receive limited information from our partners where needed to provide the Services.

How do we process your information?
We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with legal obligations.

When and with whom do we share personal information?
We may share your information in specific situations and with certain categories of third parties.

How do we keep your information safe?
We have organizational and technical measures in place to protect your information, though no system is 100% secure.

What are your rights?
Depending on your location, and who you are, applicable privacy laws may grant you certain rights regarding your personal information.

How do you exercise your rights?
You can exercise your rights by submitting a data subject access request or otherwise by contacting us.

For the full details, please review the complete privacy notice below.

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In providing the TrvlWell app and related services, including the TripAdmin and Explorer functions, we will process personal information about you such as your account details, travel arrangements and preferences, and information you upload or generate when using the Services. In some cases this may include information about your health and wellbeing or about other individuals whose details appear in documents you choose to upload.Please note that in general in the delivery of our services to you we will not process any personal data, meaning that the data we request from you through the App will not allow us to identify you. It may be that you provide us additional information, or contact us in a way that allows us to identify you, in which case we will be processing your personal data.

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TABLE OF CONTENTS

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1. WHAT INFORMATION DO WE COLLECT?

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A. Personal Information You Disclose to Us

In Short: We collect personal information that you voluntarily provide, or when you provide it as a representative of a business that wishes to engage with us.

Details:
When you express an interest in obtaining information about us or our Services, participate in activities on our Services, use our App, or contact us, you may provide:

Personal Information Provided by You:
This may include your name, phone number, and email address. In some situations you may provide us with details of your travel arrangements, health and wellness preferences and scans or images of travel‑related documents (for example boarding passes, booking confirmations, hotel confirmations, or receipts) when you use our TripAdmin features. These uploads may contain identifiers such as your booking reference, loyalty numbers or, in some cases, passport or ID details. All personal information you provide must be true, complete, and accurate. Please notify us of any changes.
When you first use TripAdmin to upload travel‑related documents, we will ask you to confirm that you understand how we will process those uploads and to consent to that processing. You can withdraw this consent at any time, but if you do so you may not be able to continue using TripAdmin upload features.

Information extracted from uploaded documents: When you upload travel‑related documents to TripAdmin, we use automated tools, including AI‑based document parsing, to extract relevant information such as flight numbers, departure and arrival locations and times, hotel names and addresses, check‑in and check‑out dates, and other itinerary details. We store this extracted information in structured form to create and maintain your trip timeline, reminders and related features.

Sensitive Information:
Some of the information you choose to provide, including information about your health, wellbeing, sleep patterns or activities, or information contained in uploaded documents, may be considered “special category” or sensitive personal data under certain laws. Where this is the case, we will only process that information with your consent, which you can withdraw at any time through the App settings or by contacting us (see Section 13).We do not process sensitive information.

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B. Information Automatically Collected

In Short: Some information, such as your IP address and browser/device characteristics, is collected automatically when you visit our Services.

Details:
We automatically collect device and usage information (e.g., IP address, browser type, operating system, language preferences, referring URLs, device name, country, location, usage data, and technical information) needed to maintain the security and operation of our Services and for analytics.
This also includes:

Log and Usage Data: Information recorded in log files.

Device Data: Information about the device you use to access our Services.

Location Data: Information about your device’s location (precise or imprecise). You can opt out by disabling your device’s location setting.

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2. HOW DO WE PROCESS YOUR INFORMATION?

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Purpose:
We process your information to:

Provide, improve, and administer our Services, including creating and managing your trip itineraries using TripAdmin, helping you discover health and wellness facilities while travelling using Explorer, and tailoring general wellbeing and jet‑lag guidance. Where we use your data to improve and develop our services, we will ensure that it is anonymised first, so that it will no longer be considered personal data.

Communicate with you.

Ensure security and prevent fraud.

Comply with legal obligations.

Process your information for other purposes with your consent.

TripAdmin and document parsing: If you choose to use TripAdmin and upload travel‑related documents, we will process those documents to extract relevant information and to build and manage your trip itinerary and related reminders. We do this using automated systems, including AI‑based document parsing tools provided by trusted third‑party service providers acting on our instructions. Although these tools are designed to be accurate, no technology is completely error‑free, and it remains your responsibility to review and confirm that any extracted trip details shown in the App (such as dates, times and locations) are correct before relying on them.

Legal Reason:
We process your information only when we have a valid legal reason.

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Please note that if you are a consumer and download the App through the Apple App Store, or Google Play, then we do not process any payment information, or, in the first instance, your personal details. The Apple/Google system will deal with those directly, and only give us a user ID number that represents your account. Without further identifying information from you directly, this will not be personal data, and any data processed through the App without additional information will therefore not constitute personal data. However, once you upload additional information the processing will generally be personal data.

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3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

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In Short:
We process your personal information only when necessary and when we have a valid legal basis, such as:

Consent:
You give us permission to process your information for a specific purpose (which you can withdraw at any time). For example, we may ask for your consent before you use TripAdmin to upload travel‑related documents, or where you choose to share information that reveals your health or wellbeing. You can withdraw this consent at any time in the App or by contacting us, but this may mean you are no longer able to use some TripAdmin features.

Contract:
We process your personal information where this is necessary to enter into or perform a contract with you, for example to create and manage your TrvlWell account, to provide TripAdmin itinerary management, to surface Explorer facilities, and to provide you with support when you contact us.

Legitimate Interests:
We may process your personal information where this is necessary for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests. This includes operating, securing and improving the App and Services, understanding how users engage with features such as TripAdmin and Explorer, and protecting our platform, content and users against misuse (for example, preventing scraping or unauthorised reuse of our facility data).

Legal Obligations:
Processing is necessary to comply with legal obligations, to fulfil or negotiate a contract with you on behalf of the organisation you represent, cooperate with law enforcement, exercise legal rights, or provide evidence in litigation.

Vital Interests:
Processing is necessary to protect your vital interests or those of another person.

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Note: For users in the EU/UK, a version of GDPR applies; for users in Canada, processing may be based on express or implied consent or other legal grounds.

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4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

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Sharing with Third Parties:
We may share your information with:

Vendors, Consultants, and Service Providers:
Third parties who perform services on our behalf. They are contractually obligated to protect your information and only process it as instructed by us.

Categories of other Third Parties:
This may include AI and document processing providers, ad networks, affiliate marketing programs, communication tools, cloud services, data analytics providers, data storage providers, finance and accounting tools, order fulfilment providers, payment processors, performance monitoring tools, product engineering and design tools, sales and marketing tools, social networks, website hosting providers, user account registration and authentication services, and testing tools.

Other Situations:

Business Transfers: In connection with mergers, acquisitions, or asset sales.

Google Maps Platform APIs: We may share location data with these APIs; you can revoke consent by contacting us.

Affiliates and Business Partners: Your information may be shared with our affiliates (including parent and subsidiary companies) and business partners under the same privacy notice.

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In all cases we will ensure that the contracts we have with third parties that involve the processing of your personal data will bind those third parties to their legal obligations to protect your data. In addition, we will not provide your data to third parties for marketing or advertising purposes without your consent.

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5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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In Short:
We use cookies and similar technologies to collect and store your information.

Details:
These tracking technologies help us:

Maintain the security and functionality of our Services.

Prevent crashes, fix bugs, save your preferences, and assist with site operations.

Provide analytics and advertising, tailored to your interests.

Opt-Out:
Third parties may use these technologies; you can opt out of targeted advertising through the options provided in our Cookie Notice.

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Example: We use Google Analytics. To opt out, visit

Google Analytics Opt-out

and refer to the

Google Privacy & Terms page

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6. HOW LONG DO WE KEEP YOUR INFORMATION?

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Retention:
We keep your personal information only as long as necessary to fulfil the purposes outlined in this notice, unless a longer retention period is required or permitted by law (e.g., for tax or accounting purposes).
Typically, no personal information is kept for longer than 2 years after our last contact with you, or if you are subscribed to the App, two years after you cease to use it. When no longer needed, your information will be deleted or anonymised.

For TripAdmin uploads we apply more specific retention rules:

• Original images or files of travel documents you upload (for example boarding passes and booking confirmations) are stored only for as long as reasonably needed to support your trip and to let you access the original if you wish. By default, we delete these original images and files no later than seven (7) days after the end of the trip to which they relate.

• The structured itinerary data we extract (such as dates, times and locations) may be retained for longer so that we can provide your trip history, recommendations and related features, in line with the general retention periods described above. Within the App, you may be able to delete uploaded document images sooner, or (where we offer this option) choose to retain them for longer for your own future reference. Where you ask us to delete an upload, we will do so unless we need to keep it for a longer period for legal or security reasons.

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7. HOW DO WE KEEP YOUR INFORMATION SAFE?

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Security Measures:
We have implemented appropriate technical and organisational security measures designed to protect your personal information.
Please note: No method of electronic transmission or storage is 100% secure. Although we work hard to protect your information, we cannot guarantee absolute security. You should access our Services only within a secure environment.

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8. DO WE COLLECT INFORMATION FROM MINORS?

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Children Under 18:
We do not knowingly collect data from or market to children under 18. By using our Services, you represent that you are at least 18 years old, or that you are the parent or guardian of a minor who has consented to that minor’s use of our Services.
If we learn that we have collected personal information from a child under 18, we will take steps to delete it promptly.

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9. WHAT ARE YOUR PRIVACY RIGHTS?

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Your Rights:
Depending on your jurisdiction (e.g., US, EEA, UK, Switzerland, or Canada), you may have rights such as:

The right to access and obtain a copy of your personal information.

The right to request rectification or erasure.

The right to restrict processing.

The right to data portability.

The right not to be subject to automated decision-making.

In some cases, the right to object to processing.

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To exercise these rights, please contact us as outlined in Section 13.

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In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 13 below.

We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

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Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 13 below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

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10. CONTROLS FOR DO-NOT-TRACK FEATURES

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Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

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11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

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In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

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• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

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• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon’s privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

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How to Exercise Your Rights. To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at privacy@trvlwell.co, or by referring to the contact details at the bottom of this document. We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.

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Request Verification. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

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Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@trvlwell.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.California 'Shine The Light' LawCalifornia Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

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If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section 13

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12. DO WE MAKE UPDATES TO THIS NOTICE?

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Updates:
We may update this privacy notice from time to time. When we do, we will revise the "Last updated" date at the top of this document. We encourage you to review this notice periodically for any changes. Where there are significant changes to this notice, we will notify you in-App in addition, to ensure that you have the chance to understand the changes prior to continuing to use our Services.

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13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

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Contact Information:
If you have any questions or concerns regarding this privacy notice, please contact us at:
Email: info@trvlwell.net

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by post at: WithU Travel Limited, Data Protection Officer, The Carriage House, Mill St, Maidstone ME15 6YE, UK

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14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information.

These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

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Privacy Notice

Last updated: 31 March 2026

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Visit our website at

https://trvlwell.co

(or any website of ours that links to this privacy notice)

Download and use the TrvlWell app (the “App”), whether from the Apple App Store, the Google Play store or otherwise

Engage with us in other related ways, including any sales, marketing, enquiry or events

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