TRIVNIX

PRIVACY POLICY

For B2B Customers, Website Users, API Users and Travellers

Prepared for compliance with Egyptian Personal Data Protection Law No. 151 of 2020 and Executive Regulations issued by Ministerial Decree No. 816 of 2025.

1. Introduction and Scope

Trivnix ("Trivnix", "we", "us", "our" or the "Company") respects privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, store, disclose, transfer and protect personal data when individuals interact with the Trivnix website, B2B reservation platform, application programming interfaces (APIs), white-label services, mobile applications, customer-support channels, booking services or other products and services operated under the Trivnix brand.

This Policy applies to business customers and their authorized users, travellers whose information is submitted in connection with bookings, website visitors, suppliers, business partners and other individuals whose personal data is processed by Trivnix. It should be read together with the applicable Trivnix Terms & Conditions and any booking-specific or commercial terms.

2. Applicable Egyptian Data Protection Framework

Where applicable, Trivnix processes personal data in accordance with the Egyptian Personal Data Protection Law No. 151 of 2020 (the "PDPL"), its Executive Regulations issued under Ministerial Decree No. 816 of 2025, relevant decisions and guidance issued by the Egyptian Personal Data Protection Center (the "PDPC"), and other applicable Egyptian laws.

Where another jurisdiction imposes mandatory privacy requirements on a particular processing activity, Trivnix will apply those requirements to the extent legally required.

3. Personal Data We Collect

3.1 Account and Business Information

●  Full name, job title and business role.

●  Business email address and telephone number.

●  Company, travel agency or organization name.

●  Business address, commercial registration or licensing information where required for onboarding and compliance.

●  Usernames, account identifiers and authentication information.

3.2 Traveller and Booking Information

●  Traveller names, nationality, date of birth and gender where required by the applicable supplier or authority.

●  Passport, identity-document, visa or travel-document information where necessary to complete a reservation.

●  Booking details, hotel stays, flights, transfers, tours, special requests and other itinerary information.

●  Information relating to accompanying travellers where supplied by the booking customer.

3.3 Payment and Financial Information

We may process payment references, billing information, transaction records, wallet balances, bank-transfer details and other information necessary to administer payments. Sensitive card information may be processed by certified third-party payment-service providers and, where so configured, is not stored directly on Trivnix systems.

3.4 Technical and Usage Information

●  IP address, browser type, device type and operating system.

●  Login times, session identifiers, pages viewed, search activity and platform interactions.

●  API requests, integration logs, security logs and error logs.

●  Referring URLs, approximate location derived from technical information, and diagnostic data.

3.5 Communications

We may keep records of communications with us, including emails, support tickets, booking messages, complaints, requests, feedback and other correspondence.

4. How We Collect Personal Data

●  Directly from you when you register, contact us, make a booking, submit traveller information or communicate with us.

●  From your employer, travel agency, corporate customer or other B2B partner that provides your information to Trivnix.

●  From hotels, airlines, destination management companies, transport providers, payment providers and other travel suppliers.

●  Automatically through cookies, logs, APIs and similar technologies when you use our website or systems.

●  From lawful public or business sources where necessary for fraud prevention, compliance, due diligence or account verification.

5. Purposes and Legal Grounds for Processing

Subject to the requirements of Egyptian law, Trivnix may process personal data for the following purposes:

●  To create, authenticate and administer B2B customer accounts.

●  To search, reserve, confirm, amend, cancel and service travel bookings.

●  To communicate booking confirmations, service notices, schedule changes and operational updates.

●  To process payments, refunds, credits, invoices and account statements.

●  To provide customer support and resolve booking issues, complaints or disputes.

●  To prevent fraud, unauthorized access, misuse, cyber incidents and other security risks.

●  To comply with tax, accounting, regulatory, judicial, law-enforcement and other legal obligations.

●  To manage supplier and commercial relationships and enforce contractual rights.

●  To analyze and improve the reliability, functionality and performance of our services.

●  To send direct electronic marketing where the required consent or other lawful basis has been obtained and applicable marketing rules are satisfied.

Depending on the processing activity and applicable law, processing may be based on the data subject’s consent, necessity to perform or administer a contract, compliance with legal obligations, protection of legitimate interests where permitted, or another lawful basis recognized under applicable law.

6. Sensitive Personal Data

Certain travel services may require information that is treated as sensitive personal data under applicable law. Trivnix will process such data only where necessary, legally permitted and subject to the additional safeguards, approvals, permits or consents required by Egyptian law. Customers should not submit sensitive data that is not required for the relevant booking or service.

7. Sharing and Disclosure of Personal Data

We may disclose personal data only as reasonably necessary for legitimate and lawful purposes, including to:

●  Hotels, airlines, transportation companies, destination management companies, tour operators and other suppliers necessary to fulfil a booking.

●  Payment processors, banks and financial-service providers necessary to process payments and refunds.

●  Technology, hosting, cybersecurity, communications, analytics and customer-support service providers acting for or with Trivnix.

●  Affiliated companies and authorized business partners where necessary to operate our services or administer a commercial relationship.

●  Professional advisers, auditors and insurers where appropriate.

●  Courts, regulators, the PDPC, law-enforcement authorities and governmental bodies where disclosure is required or permitted by law.

●  A purchaser, investor or successor entity in connection with a lawful corporate restructuring, merger, financing or sale, subject to appropriate confidentiality and data-protection safeguards.

Trivnix does not sell personal data merely for the purpose of allowing unrelated third parties to market their own products to individuals.

8. International and Cross-Border Data Transfers

Travel reservations are inherently international and may require personal data to be made available to hotels, airlines, suppliers, technology providers or other recipients located outside Egypt. Any cross-border transfer, storage, sharing, processing or access to personal data will be handled subject to the requirements of the PDPL, its Executive Regulations and applicable PDPC rules, including any required permits, licences, adequacy assessment, safeguards and data-subject consent.

Where a transfer is necessary to fulfil a booking, the relevant traveller information may be transmitted to the destination country or supplier location as required to deliver the requested travel service, subject to applicable legal requirements.

9. Data Security

Trivnix applies reasonable administrative, technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, accidental loss, destruction or unlawful processing. Depending on the relevant system and risk level, safeguards may include encryption in transit, access controls, authentication measures, monitoring, logging, backup arrangements, segregation of duties and security controls applied to service providers.

No electronic system can be guaranteed to be completely secure. Customers are responsible for safeguarding their own user credentials, API keys, devices and network environments and for promptly notifying Trivnix of suspected unauthorized access.

10. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected and for any additional period required or permitted by applicable law, accounting rules, contractual obligations, dispute-resolution requirements, fraud prevention or regulatory requirements.

When the applicable retention period expires and there is no lawful reason to continue holding the data, Trivnix will delete, anonymize or securely dispose of the information in accordance with applicable requirements.

11. Cookies and Similar Technologies

Trivnix may use cookies and similar technologies to operate secure sessions, remember preferences, understand how the website and platform are used, measure performance and, where permitted, support marketing activities.

Cookie categories may include necessary cookies, preference cookies, statistics or analytics cookies, and marketing cookies. Where consent is legally required for a category of cookies, users will be provided with an appropriate choice mechanism.

12. Direct Marketing

Trivnix may send marketing communications only in accordance with applicable Egyptian requirements. Where consent is required, we will obtain it before sending direct electronic marketing and will provide a clear and practical method to withdraw consent or opt out. Operational booking communications, security alerts, account notices and other non-marketing service messages may still be sent where necessary to provide or administer the service.

13. Your Data Protection Rights

Subject to the PDPL, its Executive Regulations, applicable exceptions and verification of identity, an individual may have rights including:

●  To know what personal data is held and how it is processed.

●  To access personal data and request a copy where legally available.

●  To request correction, completion or updating of inaccurate personal data.

●  To request deletion or erasure where the applicable legal conditions are met.

●  To object to, restrict or request cessation of certain processing where permitted.

●  To withdraw consent where processing is based on consent, without affecting processing lawfully carried out before withdrawal.

●  To object to or opt out of direct electronic marketing.

●  To submit a complaint to Trivnix and, where applicable, to the Egyptian Personal Data Protection Center.

Requests may be subject to identity verification, legal retention requirements, third-party rights and other limitations permitted by law.

14. B2B Customers and Traveller Data

Where a travel agency, corporate customer or other B2B partner provides traveller personal data to Trivnix, that customer is responsible for ensuring that it has a valid legal basis to collect and disclose the data for booking and related purposes, has provided any legally required privacy information to the traveller, and has obtained any necessary consent.

The B2B customer must limit data supplied to what is reasonably necessary for the requested service and must not submit personal data that it is not authorized to disclose.

15. Children’s Data

Trivnix is a B2B travel platform and does not knowingly permit minors to open commercial accounts. Information concerning minors may nevertheless be processed when necessary to complete a family or group travel reservation. In such cases, the B2B customer must ensure that the information is provided lawfully by an authorized parent, guardian or other person and that all applicable requirements for processing children’s data are satisfied.

16. Personal Data Breaches

Trivnix maintains procedures for identifying, assessing and responding to personal data breaches. Where required by Egyptian law or applicable PDPC rules, Trivnix will notify the competent authority and/or affected data subjects within the applicable legal timeframes and will take reasonable steps to contain and remediate the incident.

17. Third-Party Websites and Services

Our services may contain links or connections to third-party websites or services. Trivnix is not responsible for the independent privacy practices of third parties. Individuals should review the privacy notices of the relevant third-party provider before providing information directly to it.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, regulatory guidance, technology, business operations or data-processing practices. Material updates will be communicated or published through an appropriate channel. The effective date shown below will indicate the latest version.

19. Contact and Data Protection Requests

Questions, privacy requests or complaints may be sent to:

Legal Entity

Trivnix

Commercial Registration No.

775758752

Registered Address

33B Mohamed Mazhar St., Zamalek, Cairo, Egypt

Privacy / DPO Email

info@trivnix.com

General Email

Operations@trivnix.com

Website

www.trivnix.com

20. Effective Date

[INSERT EFFECTIVE DATE]

Implementation note: Before publication, Trivnix should complete all company and DPO/contact placeholders and confirm that its actual processing activities, vendors, international transfers, retention practices and consent mechanisms match this Policy and applicable PDPC licensing/permit requirements.