Dated: 15 May 2017
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, the company in charge of your information (as known as the data controller) is TransferWise Ltd of 6th Floor, The Tea Building, 56 Shoreditch High Street, London E1 6JJ. Our registration number with the Information Commissioner’s Office UK is Z2976089. If you have any questions about how we protect or use your data, please email us at firstname.lastname@example.org.
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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share this password with anyone else and not to use this password for other services or products.
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 but we cannot guarantee the security of your data during transmission, 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.
1.4 In some instances in order for us to provide our Services to you , we may need to share your information with our branches or Group Companies outside of the EEA. If you have more questions about this sharing of information, please email email@example.com.
We may collect and use the following data about you:
2.1 Information you give us.
(a) You may give us information about you by filling in forms when registering or using our Services or via correspondence e.g. email. This includes information you provide when you register to use our Services, participate in discussion boards or other social media functions on our Website or App, enter 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 for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and credit reference agencies.
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:
7.1 You have the right to ask us not to process your personal data for marketing purposes by contacting us at firstname.lastname@example.org.
7.2 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.
8.1 Subject to applicable laws, you may have the right to access information we held about you. Your right of access can be exercised in accordance with the relevant data protection legislation. Any access request may be subject to a fee of to meet our costs in providing you with details of the information we hold about you.
10.2 If you feel that we have not addressed your questions or concerns adequately, you may make a complaint with the Information Commissioner’s Office in the United Kingdom. You may access their details via https://ico.org.uk/global/contact-us/.