Dated: 09 Aug 2019
This policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this policy is legally binding when you use our Services. Check the Customer Agreement for the meaning of defined words (those with capital letters).
For the purpose of the relevant data protection regulations, Transferwise Nuqud Ltd are the "data controller" of your information. We are located in Office 3525, Level 35 of Al Maqam Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates. TransferWise has offices and associated legal entities across the world. Your personal data may be shared between TransferWise's offices as necessary or appropriate. Don't worry, we've put measures in place to keep your personal data safe whichever entity processes it. If you have any questions about how we protect or use your data, please email us at email@example.com.
1.1 We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology.
1.2 As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
1.3 We restrict access of your personal information to those employees of TransferWise who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.
We may collect and use the following data about you:
2.1 Information you give us.
(a) You may give us information about you when you sign up to use our service, e.g. when you provide us with your personal details, such as your name and email address. This also includes information you provide through your continued use of our Services, participation in discussion boards or other social media functions on our Website or App, entering a competition, promotion or survey, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, personal description and photograph.
(b) We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.
2.2 Information we collect about you. With regard to your use of our Services we may automatically collect the following information:
(a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
(b) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.
2.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them.
We use your information in the following ways:
5.1 We may share your information with selected third parties including:
5.2 We may disclose your personal information to third parties:
5.3 We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependant on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to You, you can request this by writing to firstname.lastname@example.org.
7.1 In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 5.1 that are based outside of the ADGM. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical and organisational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
8.1 We may use some instances of your data in order to customise our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymised data wherever possible. This activity has no legal effect on you.
8.2 As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
9.1 As a regulated financial institution, TransferWise is required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
9.2 We will always delete data that is not longer required by a relevant law or jurisdiction in which we operate.
9.3 Retention periods defined for the storage of your data can be found by clicking here.
10.1 You have the right to ask us not to contact you for marketing purposes by contacting us at email@example.com, or by adjusting your notification preferences in the “Settings” section of your account page.
10.2 You have the right to object to processing of your personal information by us.
10.3 You have the right to correct any personal information we hold on you that is inaccurate, incorrect, or out of date.
10.4 You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which TransferWise is subject to.
10.5 Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
11.1 Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation.
13.2 If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with the Registrar of the ADGM. You may see their contact details via the ADGM's website.