Privacy Policy

Privé is a trade name of Travel Money SAS, a French simplified joint-stock company. This Privacy Policy explains how Travel Money SAS ("Privé", "we", "us") collects, uses, shares and protects your personal data when you use our websites (withprive.com and shop.withprive.com), our app, Cami (our AI shopping assistant, including our connector for AI assistants and our messaging channels), and when you order from us. It applies wherever you live.

You can read and print this policy at any time at withprive.com/en/privacy-policy.

1. Who we are

The controller of your personal data is Travel Money SAS, société par actions simplifiée, with share capital of €3,000, RCS Paris 932 697 022, intra-community VAT number FR75 932 697 022, 14 Rue Charles V, 75004 Paris, France. Travel Money SAS buys, resells and exports the goods you order, and is the company you contract with. It is a subsidiary of Travel Money Inc., a Delaware (USA) corporation, which is not the controller of your data. Company details are in our Legal Notice.

Privacy contact: support@withprive.com, with the subject "Privacy request", or by post to Travel Money SAS, Privacy, 14 Rue Charles V, 75004 Paris, France. We have not appointed a data protection officer. If one is appointed, we will add their contact here.

We process personal data in line with:

• Regulation (EU) 2016/679 (the "GDPR");
• French Act No. 78-17 of 6 January 1978 (Loi Informatique et Libertés); and
• where they apply, US state privacy laws (section 15).

2. What this policy covers

This policy covers:

• our websites and the Privé app;
• Cami, our AI shopping assistant, on every channel: our site and app, AI assistants such as ChatGPT, Claude, Grok and Perplexity, our connector (MCP server) for those assistants, and messaging services such as iMessage, WhatsApp and Instagram;
• our Referral Program, customer support, and our emails and messages.

Separate documents cover cookies (Cookie Policy) and the rules for using Cami (Cami Terms). Third-party services you choose to use, such as an AI assistant or a messaging app, have their own privacy policies.

3. What Privé does

Privé lets customers outside the European Union, in the United States, buy European luxury goods. When you order, Travel Money SAS, under a resale agreement, buys the goods from the brand or boutique, resells them to you at an export price without French VAT, and exports and ships them to you. Doing this requires us to handle your order, payment, delivery and export data, and to keep records for the French tax and customs authorities. A Privé account is free. Cami, our AI assistant, helps you find products, compare prices and build a bag. It does not place orders or pay for you.

4. Personal data we collect

You give us:

• Account: name, email address, phone number, password (stored by our sign-in provider in hashed form), your confirmation that you are 18 or older, and your settings.
• Orders and delivery: delivery and billing address, the items you order, order history, returns, and messages about your orders.
• Payment: our payment provider (Stripe) collects your card details. We receive only a token, the card brand, the last four digits and the payment status, never your full card number.
• Cami: your messages, photos and links you send, your preferences, and, if you choose, a style profile (section 6).
• Support: what you tell us by chat, email or message. The chat on our website is Intercom. It receives your name, email, messages, and device and usage data.
• Referral Program: your referral code, the people who joined with it and the credits earned.
• Marketing choices: whether you agreed to emails or messages, and your opt-outs.

Created when you use Privé: device and browser type, IP address, log files and timestamps, pages and features used, crash and performance data, and the identifiers set by cookies or similar technologies (Cookie Policy). If you connect an AI assistant: the requests it sends us and your Privé account ID (section 6). On messaging channels: your phone number or messaging ID.

From others: AI assistants you connect (section 6), our payment provider (payment and fraud-check results), carriers (delivery status), partners and referrers (that you came through them), and the brands and boutiques we buy from (order confirmations).

Data marked as required in a form is needed to create your account or deliver an order. If you don't give it, we may not be able to provide that service.

5. Why we use your data, and our legal bases

When we rely on legitimate interests, we have checked that our interest is not overridden by your rights. You can ask us for details and you can object (section 12).

We do not sell your personal data. We never use your personal data or conversations to train AI models, ours or our vendors'. We may review conversations to check and fix answer quality (for example, correcting prompts or catalog data).

6. Cami, AI assistants and connectors

Cami is Privé's AI shopping assistant. You can use it on our website and app, by message, and inside AI assistants such as ChatGPT, Claude, Grok and Perplexity that connect to Privé through our connector (an MCP server). Using Cami and the connector is free. This section explains what we receive and keep when you do. The Cami Terms and the Cami AI Notice describe how Cami works.

Who is responsible. Travel Money SAS, 14 Rue Charles V, 75004 Paris, France, is the controller of this data for every user, wherever you live (section 1).

Legal bases. We answer connector and Cami requests because you asked us to (performance of a contract, GDPR Art. 6(1)(b)). Where you use the connector without a Privé account, and for rate limiting, security, error tracing and usage measurement, we rely on our legitimate interests in providing a safe, working service (Art. 6(1)(f)), and you can object (section 12). PostHog analytics and the Intercom messenger load when you open a page. This website does not show a cookie banner. You can block or delete cookies in your browser (Cookie Policy). Style profiles rely on your consent (Art. 6(1)(a)), which you can withdraw at any time.

What an AI assistant sends us

When you ask an AI assistant to use Privé, the assistant decides what to send us. We receive only the request it makes to our tools. Through the connector we receive:

• search queries: the words of a product search, and filters such as a brand or a maximum price;
• your state, when it is sent so we can estimate sales tax. It is not saved to your account; it may appear in request logs kept for a limited time;
• bag contents: the items and quantities in a bag link, and product IDs, for example to compare two items or build that link;
• if you have connected your Privé account (see "Signing in from an AI assistant" below), your Privé account ID; and
• technical data: the IP address of the service making the request, its user agent (which tells us which assistant family is calling, such as ChatGPT, Claude or Grok) and the time.

We do not receive your conversation with the AI assistant, its memory, your files, or your account details with that assistant. The company that runs the assistant keeps its own record of your conversation under its own terms and privacy policy, and we can't see, change or delete it.

What we keep, and for how long

Langfuse chat logging. We log Cami chats and connector tool calls in Langfuse so we can find errors and review answer quality. Personal details are masked in those logs. Langfuse logs are kept only as long as needed to find and fix errors and check answer quality, then deleted or anonymized.

We use connector requests only to answer them, keep Cami secure, prevent abuse and meet legal duties. We don't use them to build advertising profiles or send marketing, and we don't join them into a record of your conversations.

Who processes this data for us

We use service providers that act on our instructions under contract. For Cami and the connector, that includes:

• OpenRouter (model provider: routes Cami's requests to language models that write replies and may help understand a search);
• Langfuse (logs Cami chats and connector requests, with personal details masked, so we can find errors and check answer quality);
• PostHog (product analytics: which tools were used and whether they succeeded);
• Resend (sends service and transactional email; Twilio SendGrid sent that email before Resend);
• Supabase (database and sign-in, including the OAuth sign-in described below);
• Vercel (hosting, edge network and server logs); and
• Photon (iMessage relay: delivers Cami messages to and from iMessage).

Inside third-party AI assistants, the assistant's own AI writes the replies, not ours. OpenRouter and the model providers it routes to generate Cami's replies on our own website, app and messaging channels. Section 8 lists these providers again, with the others that process personal data for orders and the website, and the transfer safeguard for each.

Several of these providers are based in, or process data in, the United States. Because Travel Money SAS is established in France, the GDPR applies to all of this data, including data about US users. When we transfer it outside the EEA, we use the safeguards described in section 9.

No sale, and no AI training

• We do not sell your personal data or share it for cross-context behavioral advertising.
• We never use your personal data or conversations to train AI models, ours or our vendors'. We may review conversations to check and fix answer quality (for example, correcting prompts or catalog data).

Signing in from an AI assistant (OAuth)

Some assistants let you connect your Privé account so Cami can work with it. Connecting is optional. Without it, Privé's catalog tools work without an account. When you connect:

1. the assistant sends you to Privé to sign in, using our sign-in service (Supabase Auth);
2. a Privé consent screen shows which assistant is asking and what it will be able to do, for example "Confirm who you are" or "See your email address"; and
3. only if you choose Allow, the assistant receives a token for your Privé account. Privé never receives your password for the assistant, and the assistant never receives your Privé password.

When you sign in, we receive the name, email address and phone number on your Privé account. With a token, the assistant's requests to Privé carry your Privé account ID. If the consent screen says so, the assistant can also see that name, email address or phone number. A token is kept only as long as needed for that connection, then it expires. You can disconnect at any time by removing Privé in the assistant's settings or by emailing support@withprive.com, and we will revoke its access.

Style profile

Style-profile drafts are created only with your consent. We do not offer them to anyone under 18. If you ask Cami to save your style preferences, Cami sends us only the style details in its summary: taste, style lean, brands you love or avoid, categories, item types, colors, budget ranges, size labels and occasions. It doesn't send your name, contact details or the conversation. We keep this as a private draft that isn't linked to your name, email or any account, and give you a private link. If you open the link within 7 days and confirm, the preferences are added to your free Privé account and used only to tailor what you see on Privé and what Cami suggests. They stay until you delete them or your account. If you don't, the link stops working after 7 days and the draft is permanently deleted, usually within an hour. Anyone with the link can claim the draft, so don't share it. You can delete a draft at any time from the link or by asking Cami. We don't sell style preferences, use them for ads on other sites or to set prices, or share them with brands or other retailers.

Deleting your data and your choices

• To delete data we hold about your use of Cami or the connector, or your Privé account, email support@withprive.com with the subject "Privacy request". We will confirm when it's done.
• To stop an assistant from sending requests on your behalf, remove Privé in that assistant's settings.
• To delete your conversation with the assistant itself, use that assistant's own controls.
• You also have the rights described in section 12, including the right to object and to complain to the CNIL.

7. Automated decisions and profiling

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you (GDPR Art. 22).

• Cami's suggestions. Cami uses AI to choose products and wording based on what you ask and, if you've saved one, your style profile. That's personalization (a form of profiling), not a decision about you. You can ignore it, ask Cami to forget your preferences, delete your style profile, or object.
• Style profiles are used only to tailor what you see on Privé and what Cami suggests. We don't use them to set prices, to decide whether you can buy, for advertising on other sites, or to share with brands or other retailers.
• Order checks. We check orders against fixed rules (an 18+ account, a US delivery address, and any minimum order value shown at checkout). Our payment provider may also screen payments for fraud automatically. If an order or payment is declined and you think it's wrong, contact us. A person will review it, and you can explain your view and contest the outcome.

8. Who we share data with

We don't sell your personal data, and we share it only as described here.

Service providers (processors) act only on our instructions, under a contract that meets GDPR Art. 28. Each purpose below is one line. The transfer safeguard for a provider outside the EEA is described in section 9.

Resend sends service and transactional email. Twilio SendGrid sent that email before Resend and may still hold messages it sent. Those messages are kept only as long as needed for the email that was sent, then deleted or anonymized.

Intercom provides the customer support chat on our website. Intercom R&D Unlimited Company, in Ireland, and Intercom, Inc., in the United States, process your name, email, messages, and device and usage data for that chat. Because Intercom, Inc. is in the United States, that transfer uses the safeguards in section 9, the same way we transfer data to our other US providers. Support messages are kept only as long as needed to handle your request, then deleted or anonymized.

Google Fonts serves the typefaces on this website. The browser loads them from Google, and Google receives that request, including the IP address. We do not use Google for sign-in. That transfer uses the safeguards in section 9.

Other recipients that use data for their own purposes, under their own policies:

• Carriers and customs brokers, to ship and clear your order. They receive your name, delivery address, phone number and the shipment details.
• Tax and customs authorities in France (DGFiP, French customs) and the United States (US Customs and Border Protection), as the law requires for export and import.
• Brands and boutiques we buy from, so we can purchase the goods under the resale agreement. We do not send them your payment card number.
• Awin (affiliate network), only if you arrived through a partner and accepted affiliate cookies: the order reference and amounts, not your name or contact details (Cookie Policy).
• AI assistants and messaging platforms you choose to use (for example OpenAI, Anthropic, xAI, Perplexity, Meta, Apple). They receive our replies to your requests and handle your conversation under their own terms.
• Travel Money Inc., our US parent company, is not the controller. Its staff can see customer data when they operate Privé, including through the Apple Developer account, which Travel Money Inc. holds. That access is an intra-group transfer. Because Travel Money Inc. is in the United States, the transfer is made under the EU Standard Contractual Clauses.
• Professional advisers (lawyers, accountants, auditors), under a duty of confidentiality.
• Courts, regulators and law enforcement, when the law requires it or to protect our rights, and, where legally allowed, we will tell you.
• A buyer or successor, if we restructure or sell all or part of our business, who must keep protecting your data as this policy describes.

9. International transfers

We're based in France, and some recipients are in, or process data in, the United States and other countries outside the European Economic Area (EEA). Because the GDPR applies to all our processing, these rules cover data about every user, including users in the US. When we transfer personal data outside the EEA, we use one of these safeguards:

• the EU-US Data Privacy Framework (DPF), for US recipients certified under it (European Commission adequacy decision of 10 July 2023);
• the EU Standard Contractual Clauses (SCCs) (Commission Decision (EU) 2021/914), with extra measures where needed after a transfer assessment, for recipients not certified under the DPF; or
• where neither applies, a transfer that is necessary to perform your contract, for example giving a US carrier and US customs your delivery details so we can ship your order (GDPR Art. 49(1)(b)).

For each provider in section 8, we use one of the safeguards above. You can ask for a copy of the relevant safeguards at support@withprive.com.

10. How long we keep data

When a period ends, we delete or anonymize the data. Data we must keep only for a legal obligation is archived with restricted access. Where a row states a purpose, that purpose is how long we keep the data. For more detail on a category, email support@withprive.com.

11. Security

We use technical and organizational measures to protect personal data, including encryption in transit, access controls limited to staff and providers who need it, masking of personal details in AI traces, and contracts with our providers that require confidentiality and security. If a breach is likely to put your rights at risk, we will notify the CNIL and, where required, you.

12. Your rights

Wherever you live, you have these rights under the GDPR:

• Access: get a copy of your data and information about how we use it.
• Rectification: correct inaccurate or incomplete data.
• Erasure: have your data deleted, unless we must keep it (for example invoices).
• Restriction: ask us to pause using your data in certain cases.
• Portability: receive data you gave us, which we process by contract or consent, in a structured, machine-readable format, or have it sent to another company.
• Objection: object at any time to processing based on our legitimate interests, on grounds relating to your situation. Object at any time, without giving a reason, to direct marketing and any profiling linked to it.
• Withdraw consent at any time, as easily as you gave it (for example the unsubscribe link, STOP, cookie settings, or deleting your style profile). This doesn't affect what we did before.
• Not be subject to solely automated decisions with legal or similarly significant effects, and get human review (section 7).
• Instructions after death: give us instructions on what happens to your data after your death (French Loi Informatique et Libertés, art. 85).

How: email support@withprive.com (subject "Privacy request") or write to us (section 1). It's free. We reply within one month. We can extend that by two more months for complex requests, and if we do we'll tell you why. We may ask you to confirm your identity, for example from the email address on your account.

Complaints: you can complain to a data protection authority. In France that's the CNIL (Commission Nationale de l'Informatique et des Libertés), 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr. If you live in another EU country, you can also complain to your local authority. We'd appreciate the chance to sort it out first.

13. Marketing

We send marketing emails only if you agreed, or, if you're a customer, about similar Privé offers, with an easy opt-out in every message. We send marketing or reminder texts and WhatsApp messages only with your consent. Reply STOP to any text to stop them. We don't sell or rent your contact details, or give them to others for their own marketing.

14. Children

Privé, including Cami and style profiles, is only for adults. You must be 18 or older to create an account, order, or save a style profile, and we ask you to confirm this at sign-up. We don't knowingly collect data from anyone under 18. If you think a minor has given us personal data, email support@withprive.com and we'll delete it. AI assistants that connect to Privé must not use our connector for users under 18.

15. Notice for US residents (including California)

This section adds to the rest of this policy for residents of US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the CPRA ("CCPA"), where those laws apply to us. For these laws, Travel Money SAS is the "business" responsible for your personal information.

What we collect (past 12 months), by CCPA category:

• identifiers (name, email, phone, IP address, account ID);
• customer records (delivery and billing address, payment token);
• commercial information (orders, returns, referral credits);
• internet or other electronic activity (usage, connector requests, Cami interactions);
• approximate geolocation (US state, from your address or a search filter);
• inferences (style profile, if you save one);
• sensitive personal information: account log-in credentials, used only to sign you in and keep your account secure.

We collect these from the sources, and use them for the purposes, in sections 4 to 6. We keep them for the periods in section 10. We disclose each category for business purposes to the service providers and other recipients in section 8.

Sale and sharing. We do not sell personal information, and we do not share it for cross-context behavioral advertising. If an order comes through an affiliate partner, Awin may receive the order reference and amounts described in section 8, so the partner can be credited. This website does not show a cookie banner. We honor Global Privacy Control signals as a request to opt out of sale or sharing. We have no actual knowledge of selling or sharing personal information of anyone under 16. We use sensitive personal information only for purposes the CCPA permits, so the "limit" right doesn't apply.

Your rights:

• know and access what we collect, use and disclose;
• delete;
• correct;
• opt out of sale or sharing, and of targeted advertising and significant profiling (other states);
• not be discriminated against for using these rights.

To use them, email support@withprive.com (subject "US privacy request"). We'll verify your request by matching it to your account details. An authorized agent may ask for you with your signed permission. If we refuse, you can appeal by replying to our answer, and if you live in a state that provides it, you can complain to your state Attorney General.

Referral Program (notice of financial incentive). Referral credits are an incentive tied to signing up and referring others. Taking part is optional and you can stop at any time (Referral Program Terms). We value the referral at the credit amount, which reflects what we expect a new customer's first order to be worth to us.

16. Changes to this policy

We may update this policy. We'll post the new version here with its date and, for material changes, tell you by email or in Cami before they take effect. Unless the law requires otherwise, updates take effect 14 days after publication.

17. Contact

Travel Money SAS, Privacy, 14 Rue Charles V, 75004 Paris, France · support@withprive.com (subject "Privacy request").