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Privacy Policy

1. Introduction

1.1 This website is owned and operated by Wirex Limited (“Wirex”). Wirex is committed to its Website users’ and visitors’ privacy. This policy explains how Wirex will handle any personal data submitted by you to Wirex through your use of the Wirexapp.com or Wirexapp.sg website (in each case the “Website”). Any capitalized terms used herein shall be interpreted in accordance with the definitions set out in Wirex’s Website General terms of Service, unless otherwise stated. “Personal data” is defined in Article 4(1) of the GDPR as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

1.2 This Privacy Policy should be read in conjunction with:
a) Wirex’s Website General terms of Service, available [HERE];
b) The relevant Wirex Card Issuer Terms, as described at Clause 1.6 below;
c) Wirex’s Supplemental Terms as may apply to your territory, available [HERE]
d) Wirex’s Cryptocurrency-specific Terms, available [HERE];
e) Wirex’s Card Terms, available [HERE];
f) Wirex’s Fee Terms, available [HERE].

1.3 When signing up for a Wirex Account via the Website, the Website will ask you to specify certain privacy preferences which affect how Wirex will process your personal data. By selecting the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.4 Wirex will ask you to consent to Wirex’s use of cookies in accordance with the terms of this policy when you first visit Wirex’s website and/ or create a Wirex Account. By continuing to use Wirex’s website and agreeing to this policy, you consent to Wirex’s use of cookies in accordance with the terms of this policy.

1.5 Wirex is registered in England and Wales under company registration number 09334596, and Wirex’s registered office is at Floor 5, 25 Old Broad Street, London EC1N 2HN.

2. Contacting Us

2.1 You can contact Wirex:
(a) using Wirex’s website contact form; or
(b) by email, using [the email address published on Wirex’s website from time to time.] – clarify

2.2 For queries relating to this policy, please contact: privacy@wirexapp.com

3. How your personal data is used by Wirex

3.1 In this Section 3 Wirex sets out:
(a) the general categories of personal data that Wirex may process;
(b) the purposes for which Wirex may process personal data; and
(c) the legal bases of Wirex’s processing of your personal data.

3.2 Wirex may process:
(i) usage data – The usage data may include browser type and version, operating system and date and time of your visit. The source of the usage data is our analytics tracking system as updated by Wirex from time to time. This usage data may be processed for the purposes of analysing the use of the Website and Wirex Services. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of the Wirex Services for illicit activities as well as improving the Website and Wirex Services.
(ii) profile data – Wirex may process personal data included in your personal profile on Wirex’s website. Your profile data will include, as a minimum, your name, address, telephone number, email address, date of birth and country of residence. Profile data may be processed for the purposes of enabling and monitoring your use of the Website and Wirex Services. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely monitoring usage of the Wirex Services for illicit activities as well as improving the Website and Wirex Services.
(iii) account data – Wirex may process your Wirex Account data, which will include your name and email address, as well as your registered address and photo identification details. The source of the account data is the data which you enter when signing up for a Wirex Account. The account data may be processed for the purposes of operating Wirex’s Website, providing the Wirex Services, ensuring the security of Wirex’s Website and Wirex Services, monitoring any illicit or suspicious transactions undertaken using the Wirex Services and also communicating with you. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Wirex’s legitimate interests, namely monitoring usage of the Wirex Services for illicit activities as well as improving the Website and Wirex Services.
(iv) publication data – Wirex may process information that you post for publication on the Website or through Wirex’s services. The publication data may be processed for the purposes of enabling such publication and administering the Website and the Wirex Services. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Wirex’s legitimate interests, namely monitoring usage of the Wirex Services against illicit activities as well as improving the Website and Wirex Services.
(v) service data – Wirex may process personal data that you provide in the course of the use of the Wirex Services. The service data may include ATM data, transaction amounts and merchant information. The source of the service data is your use of the Wirex Services, including, without limitation, the Wirex Transactions you undertake. The service data may be processed for the purposes of operating Wirex’s website, providing Wirex’s services, ensuring the security of Wirex’s website and services, maintaining back-ups of Wirex’s databases and communicating with you. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, as well as Wirex’s legitimate interests, namely monitoring usage of the Wirex Services for illicit activities as well as improving the Website and Wirex Services.
(vi) transaction data – Wirex may process information relating to Wirex Transactions that you enter into with us and/or through the Website. The transaction data may include your contact details, your Wirex Card details and specific data concerning each Wirex Transaction you enter into, merchant and pricing information. The transaction data may be processed for the purpose of monitoring the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and Wirex and/or taking steps, at your request, to enter into such a contract, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely Wirex’s interest in the proper administration of the Website and business, as well as Wirex’s legitimate interests, namely monitoring usage of the Wirex Services against illicit activities as well as improving the Website and Wirex Services.
(vii) enquiry data – Wirex may process information contained in any enquiry you submit to us regarding Wirex Services. The enquiry data may be processed for the purposes of offering, marketing and selling other relevant Wirex products and/or services to you. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis.
(viii) correspondence data – Wirex may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. The Website will also generate metadata associated with communications made using the Website’s contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis, namely the proper administration of the Website and Wirex’s business and communications with Wirex’s users.
(ix) notification data – Wirex may process information that you provide to us for the purpose of subscribing to Wirex’s email notifications and/or newsletters The notification data may be processed for the purposes of sending you relevant notifications and/or newsletters. The legal basis for this processing is your consent, as well as Wirex’s legitimate interests and the legal requirements to which it is subject to on an ongoing basis for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
((i) to (ix) being “Relevant Data”)

3.3 Wirex may also process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is Wirex’s legitimate interests, namely the protection and assertion of Wirex’s legal rights, your legal rights and the legal rights of others.

3.4 In addition to the specific purposes for which Wirex may process your personal data set out in this Section 3, Wirex may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which Wirex is subject, or in order to protect your vital interests or the vital interests of another natural person.

3.5 Please do not supply any other person’s personal data to us, unless Wirex request in writing that you do so.

4. Providing your personal data to others
4.1 Wirex may disclose any or all of Relevant Data to:
(a) any member of Wirex’s group of companies (this means Wirex’s subsidiaries, Wirex’s ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy; and
(b) to Wirex’s insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
(c) subcontractors, insofar as reasonably necessary for the purposes of those subcontractors performing their obligations to Wirex to allow Wirex to provide the Wirex Services.
(d) Wirex’s partners, including but not limited to each relevant Wirex Card Issuer and Payment Processor.

4.4 Financial transactions relating to the Wirex Services are handled by Wirex’s payment services providers. Wirex will share transaction data with Wirex’s payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.5 In addition to the disclosures of Relevant Data set out in this Section 4, Wirex may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which Wirex is subject, or in order to protect your vital interests or the vital interests of another natural person.

5. International transfers of your personal data
5.1 In this Section 5, Wirex provide information about the circumstances in which your personal data may be transferred to our third party partners as data processors, who are located in the United States of America.

5.2 Wirex and Wirex’s other Group Members have offices and facilities in the United Kingdom, Ukraine, Japan and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries that are outside of the EEA. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

5.3 Other than the UK, certain hosting facilities for Wirex’s Website are situated in Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

5.4 Certain of Wirex’s partners and service providers are situated outside of the EEA, namely in the United States of America and Singapore. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of binding corporate rules between Group Members.

6. Retaining and deleting personal data
6.1 This Section 6 sets out Wirex’s data retention policies and procedure, which are designed to help ensure that Wirex complies with Wirex’s legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that Wirex process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 Wirex will retain and delete your personal data for the longer of (i) a period of 5 years or (ii) such other period as required to comply with applicable legislation, following the date on which you close your Wirex Account, at the end of which period it will be deleted from Wirex’s systems.

6.4 Notwithstanding the other provisions of this Section 6, Wirex may retain your personal data where such retention is necessary for compliance with a legal obligation to which Wirex is subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments
7.1 Wirex may update this policy from time to time by publishing a new version on Wirex’s Website. You should check this page occasionally to ensure you are happy with any changes to this policy. Wirex may notify you of changes to this policy by email.

8. Your rights
8.1 In this Section 8, Wirex have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in Wirex’s summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.4 Notwithstanding the other provisions of this Section 6, Wirex may retain your personal data where such retention is necessary for compliance with a legal obligation to which Wirex is subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 Wirex may update this policy from time to time by publishing a new version on Wirex’s Website. You should check this page occasionally to ensure you are happy with any changes to this policy. Wirex may notify you of changes to this policy by email.
8. Your rights
8.1 In this Section 8, Wirex have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in Wirex’s summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not Wirex processes your personal data and, where Wirex does, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, Wirex will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; Wirex no longer need the personal data for the purposes of Wirex’s processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Wirex may continue to store your personal data. However, Wirex will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to Wirex’s processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, Wirex will cease to process the personal information unless Wirex can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to Wirex’s processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, Wirex will cease to process your personal data for this purpose.

8.9 You have the right to object to Wirex’s processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for Wirex’s processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that Wirex’s processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for Wirex’s processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us at support@wirexapp.com.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that Wirex store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that Wirex uses

10.1 Wirex use cookies for the following purposes:
(a) tracking devices within Wirex’s website (cookies used for this purpose are: wx-amplitude-device-id);
(b) saving unique identifier of the device that used to navigate through Wirex’s website (cookies used for this purpose are: wx-deviceId);
(c) store session identifier (cookies used for this purpose are: wx-session);
(d) store user last activity time (cookies used for this purpose are: wx-afkSince).

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you may not be able to use all the features on Wirex’s Website.