Privacy Policy

How we collect, use, share, and protect personal information.

On this page · 23 sections

Last updated: 24 April 2026

This Privacy Policy explains how FXN HOLDINGS LIMITED ("FXN", "we", "us", or "our") collects, uses, shares, stores, and protects personal information when you use Originfacts at www.originfacts.com and any related pages, features, newsletters, reviews, comments, ratings, photos, forums, travel tips, comparison tools, and affiliate links (the "Website").

This Website is operated by FXN HOLDINGS LIMITED, a private limited company registered in England and Wales under company number 16134139, with registered office at 61 Bridge Street, Kington, HR5 3DJ, United Kingdom.

We are the controller of personal information we collect through the Website, except where another organisation explains that it is independently responsible for its own processing.

1. Important travel affiliate notice

Originfacts is a travel information and affiliate aggregation website. We do not directly sell travel bookings, take payment for bookings, issue tickets, operate airlines, operate hotels, rent vehicles, provide tours, or process booking refunds.

When you click an affiliate link, booking link, widget, advertisement, or comparison result, you may leave Originfacts and visit a third-party website. That third-party provider may collect and use your personal information under its own privacy policy. We are not responsible for third-party privacy practices.

2. Contact details

Controller: FXN HOLDINGS LIMITED Company number: 16134139 Registered office: 61 Bridge Street, Kington, HR5 3DJ, United Kingdom Email: support@fxnholdings.com Phone: +44 7413 408585 Website: www.originfacts.com ICO registration reference: ZB940664

EU representative, if required: [INSERT EU REPRESENTATIVE NAME AND CONTACT DETAILS, OR CONFIRM EXEMPTION WITH LEGAL COUNSEL]

For privacy requests, email support@fxnholdings.com with the subject line "Privacy Request".

3. Personal information we collect

Depending on how you use the Website, we may collect the following information.

3.1 Information you provide directly

This may include:

name;
email address;
phone number, if you contact us by phone or provide it in a form;
message contents and correspondence;
newsletter subscription details;
account details, username, display name, password credentials, profile information, and preferences, if accounts are enabled;
reviews, comments, ratings, photos, forum posts, travel tips, and other User Content;
information you submit in support, complaint, illegal-content, copyright, moderation, or privacy requests; and
consent choices and communication preferences.

3.2 Information collected automatically

When you use the Website, we may collect:

IP address;
device type, browser type, operating system, screen size, language, and approximate location;
pages viewed, links clicked, referring page, time spent, search terms, travel search criteria, and interaction events;
cookie identifiers, analytics identifiers, affiliate click identifiers, and similar identifiers;
log data, security events, error reports, and diagnostic data; and
information about whether you accepted, rejected, or changed cookie preferences.

3.3 Information from third parties

We may receive limited information from:

Travelpayouts and travel affiliate partners, such as click, referral, conversion, and commission information;
Google Analytics, such as aggregated website analytics and event data;
Mailchimp, such as newsletter subscription status, email engagement, unsubscribe status, and campaign analytics;
hosting, security, and technical service providers, including Vercel; and
users who report content, submit complaints, or contact us about your content.

3.4 Sensitive information

We do not intentionally request sensitive information such as passport numbers, national identity numbers, payment card details, precise health information, religious beliefs, political opinions, biometric data, or information about children.

Do not submit sensitive information through reviews, comments, forms, forum posts, photos, or messages unless we specifically request it and explain why it is needed.

4. How we use personal information and our lawful bases

We use personal information for the following purposes.

4.1 To operate the Website

We use information to provide pages, comparison tools, affiliate links, forms, user accounts, reviews, comments, forums, and other Website features.

Lawful basis where UK/EU data protection law applies: performance of a contract, legitimate interests, and, where required, consent.

4.2 To respond to you

We use contact details and message contents to respond to enquiries, support requests, legal notices, content complaints, privacy requests, and accessibility feedback.

Lawful basis: legitimate interests, legal obligation, and, where applicable, performance of a contract.

4.3 To send newsletters and travel updates

If you subscribe, we use your email address and preferences to send newsletters, travel tips, promotions, affiliate offers, destination content, and related updates through Mailchimp.

Lawful basis: consent, or another lawful basis where applicable law permits.

You can unsubscribe at any time using the unsubscribe link in our emails or by contacting us.

4.4 To analyse and improve the Website

We use Google Analytics and similar tools to understand how users interact with the Website, improve content, detect errors, measure performance, and understand travel-resource demand.

Lawful basis: consent where required for analytics cookies and similar technologies; otherwise legitimate interests where lawful.

We do not permit Google Analytics to receive information that Google policies treat as personally identifiable information, such as email addresses or phone numbers.

4.5 To manage affiliate links and commissions

We use affiliate links, tracking identifiers, referral data, and conversion data to understand whether a user clicked a link and whether a commission may be payable to us.

Lawful basis: consent where required for affiliate tracking cookies or similar technologies; otherwise legitimate interests in operating an affiliate-funded travel information service.

4.6 To display, moderate, and manage User Content

If you post reviews, ratings, comments, photos, forum posts, or travel tips, we process your User Content, account details, metadata, and moderation history to display content, prevent abuse, detect fake reviews, enforce our Terms, handle reports, and maintain trust in the Website.

Lawful basis: performance of a contract, legitimate interests, legal obligation, and, where required, consent.

4.7 To prevent fraud, abuse, and security incidents

We use technical logs, IP addresses, account data, cookie identifiers, device information, and moderation records to protect the Website, users, and third parties from spam, fraud, fake reviews, cyberattacks, scraping, unlawful content, and misuse.

Lawful basis: legitimate interests and legal obligation.

4.8 To comply with law and enforce rights

We may use information to comply with legal obligations, respond to lawful requests, protect rights, enforce our Terms, handle disputes, preserve evidence, and cooperate with regulators or authorities where legally required.

Lawful basis: legal obligation and legitimate interests.

5. Cookies, analytics, and similar technologies

We use cookies and similar technologies as described in our Cookie Policy.

In regions where consent is required, we will ask for consent before setting non-essential analytics, affiliate, advertising, or similar cookies.

You can change cookie preferences through the Website's cookie controls, your browser settings, and, where available, privacy preference signals such as Global Privacy Control.

6. Google Analytics

We use Google Analytics to measure Website usage and improve the Website.

Google Analytics may collect information such as device information, browser information, approximate location, pages visited, interactions, and cookie identifiers. Google Analytics uses cookies and similar technologies to distinguish visitors and report site usage statistics.

We use Google Analytics in accordance with Google's applicable terms and privacy controls. We aim not to send Google information such as email addresses, phone numbers, or other direct identifiers through Analytics.

You can opt out of Google Analytics by using our cookie controls where available, browser settings, or Google's opt-out tools.

7. Mailchimp newsletters

We use Mailchimp to manage email newsletters and marketing communications.

If you subscribe, Mailchimp may process your email address, name if provided, subscription preferences, email engagement information, IP address, signup time, unsubscribe status, and related technical information.

Mailchimp may process information in the United States and other countries. We rely on Mailchimp's data processing terms and transfer safeguards where required.

You can unsubscribe at any time using the unsubscribe link in an email or by contacting us.

8. Travelpayouts and affiliate tracking

We participate in the Travelpayouts affiliate network.

When you click affiliate links, use affiliate widgets, or interact with travel-provider links, Travelpayouts, travel brands, and other third-party providers may process information such as click identifiers, referral URLs, device information, booking or conversion events, commission information, and cookie identifiers.

Travelpayouts and travel providers may act as independent controllers or processors depending on the context. Their own terms and privacy notices apply to their websites, tools, and tracking technologies.

9. Vercel and hosting

The Website is custom-coded and currently hosted using Vercel.

Hosting and infrastructure providers may process technical logs, IP addresses, device information, security events, and related data needed to deliver, secure, and maintain the Website.

10. User Content is public

Reviews, comments, ratings, photos, forum posts, travel tips, usernames, display names, and other User Content may be visible to the public.

Do not post information that you want to keep private. Do not post personal information about other people unless you have permission and a lawful basis to do so.

We may remove or anonymise User Content where required by law, our Terms, moderation rules, privacy rights, safety needs, or legal risk.

We may share personal information with:

hosting, infrastructure, database, security, and technical service providers;
analytics providers, including Google Analytics;
email marketing providers, including Mailchimp;
affiliate networks and travel partners, including Travelpayouts, where necessary for affiliate tracking and commission attribution;
moderation, support, legal, accounting, compliance, and professional advisers;
regulators, courts, law enforcement, government authorities, and dispute bodies where legally required or reasonably necessary;
third parties involved in a business sale, merger, restructuring, financing, or transfer of assets; and
other users or the public where you submit public User Content.

We do not sell personal information for money.

Some privacy laws define "sale", "sharing", or "targeted advertising" broadly. If our analytics, affiliate, or advertising technologies are considered a sale, sharing, or targeted advertising under applicable law, you may have opt-out rights as explained below.

12. International transfers

We are based in the United Kingdom and use service providers that may process information in the United Kingdom, European Economic Area, United States, Canada, Singapore, and other countries.

Where required, we use appropriate safeguards for international transfers, such as adequacy regulations, adequacy decisions, data processing agreements, standard contractual clauses, Data Privacy Framework certifications where applicable, or other lawful transfer mechanisms.

13. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Our usual retention periods are:

contact and support messages: up to 24 months after the last interaction, unless needed longer for disputes or legal compliance;
newsletter data: until you unsubscribe or we remove inactive subscribers, plus suppression records to ensure we respect unsubscribe requests;
user accounts: while the account remains active and for a reasonable period afterwards for security, dispute, and legal purposes;
User Content: while published on the Website and for a reasonable period afterwards for moderation, backup, dispute, and legal purposes;
moderation and abuse-prevention records: as long as needed to protect the Website and users;
cookie consent records: as long as needed to prove and manage consent choices;
analytics data: according to our Google Analytics retention settings;
affiliate tracking and commission records: as long as needed for attribution, reporting, accounting, tax, audit, and dispute purposes; and
legal and compliance records: as long as required by applicable law.

14. Your privacy rights

Depending on your location and the law that applies, you may have rights to:

access personal information we hold about you;
receive information about how we use personal information;
correct inaccurate or incomplete information;
delete personal information;
restrict or object to processing;
withdraw consent where processing is based on consent;
request data portability;
opt out of direct marketing;
opt out of sale, sharing, targeted advertising, or profiling where applicable;
appeal or complain about our response where applicable;
complain to a data protection authority; and
nominate or authorise another person to act for you where applicable law allows.

These rights may be limited in some circumstances, for example where we need information for legal compliance, security, fraud prevention, dispute handling, freedom of expression, public User Content moderation, or legitimate business purposes.

To exercise rights, email support@fxnholdings.com with the subject line "Privacy Request".

We may need to verify your identity before responding. We will respond within the timeframe required by applicable law.

15. UK and EEA rights

If UK or EU/EEA data protection law applies, you may have rights of access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and complaint to a supervisory authority.

You have the right to object to direct marketing at any time.

You also have the right to object to processing based on legitimate interests. We will stop processing unless we have compelling legitimate grounds or need the information for legal claims.

UK users may complain to the Information Commissioner's Office. EEA users may complain to their local data protection authority.

16. US state privacy rights

If you are in a US state with applicable privacy laws, you may have rights to know, access, delete, correct, obtain a portable copy of your information, and opt out of sale, sharing, targeted advertising, or certain profiling.

We do not sell personal information for money. However, some analytics, affiliate, and advertising technologies may be treated as "sharing" or "targeted advertising" under some US state privacy laws if configured in that way.

You may opt out by using our cookie preference controls, by enabling a recognised browser-based opt-out preference signal where supported, or by emailing support@fxnholdings.com with the subject line "US Privacy Opt-Out".

17. Canadian, Australian, New Zealand, Singapore, India, UAE, and Saudi Arabia privacy rights

Depending on where you live, you may have additional rights under local privacy laws, including rights to access, correct, withdraw consent, complain, request information about processing, object to certain processing, or request deletion.

We will handle requests according to the law that applies to your request.

18. Marketing emails

We send marketing emails only where we have a lawful basis to do so.

Every marketing email will identify us or the relevant sender and provide an unsubscribe method.

You can unsubscribe at any time. We may keep your email address on a suppression list so that we do not send further marketing emails to that address.

19. Children's privacy

The Website is intended for users who are old enough to enter binding contracts.

We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact support@fxnholdings.com and we will take appropriate action.

20. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration, and disclosure.

No website, hosting provider, email service, analytics system, or online transmission is completely secure. You are responsible for keeping your account details secure and for using caution when posting public User Content.

21. Automated decision-making

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects about you.

We may use automated or semi-automated tools to detect spam, abuse, fake reviews, suspicious activity, security threats, or Website errors. Human review may be used where appropriate.

22. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new "Last updated" date.

If changes are material, we may provide additional notice where required by law or where we consider it appropriate.

23. Contact us

For privacy questions, requests, or complaints, contact:

FXN HOLDINGS LIMITED 61 Bridge Street Kington, HR5 3DJ United Kingdom

Email: support@fxnholdings.com Phone: +44 7413 408585 Website: www.originfacts.com