Dated: 26 July 2016
We use information that we collect from or about our customers in accordance with our Consumer Privacy Notice, which provides choices about our sharing and use of information.
We may collect, through the means described here, the following information:
Personal Information you give us. “Personal Information” is information that identifies you as an individual or relates to an identifiable person. We collect your Personal Information when you provide it to us, such as when you register to use our Services, participate in discussion boards or other social media functions on the Services, enter a competition, promotion or survey, report a problem with our Services or otherwise communicate with us. The Personal 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), and social security number.
We may also need to collect additional commercial and/or identification information from you, such as if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering or other obligations under applicable law.
Other Information we collect. “Other Information” is information that does not reveal your specific identity or does not directly relate to an individual. We may automatically collect the following information when you use the Services:
Details of the transactions you carry out on when using our Services, including the country from which the transaction originates;
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, Internet browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform;
Information about your use of the Services, including the full Uniform Resource Locators (URL) clickstream to, through and from the Services (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.
We may aggregate Personal Information. Such aggregated information does not personally identify you or any other user of the Services. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code.
Information we receive from other sources. We work closely with third parties and may receive information about you from them. These third parties may include, 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; credit reference agencies; public databases; and social media platforms.
At this time we do not respond to browser do-not-track signals.
Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
We may use Adobe Flash Local Shared Objects (“Flash LSOs”) and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Services.
We may use your Personal Information in the following ways:
to carry out our obligations relating to your contracts and transactions with us and to provide you with the information, products and services that you request from us, as well as related customer service;
to notify you about changes to our Services or to send you other administrative information;
to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Services and so that they are presented in the most effective manner;
to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
to allow you to participate in interactive features of our Services, when you choose to do so;
to facilitate social sharing functionality; and
consistent with choices that may be available to you, to provide you with information about other goods and services we feel may interest you.
We may also use and disclose Personal Information as we believe necessary or appropriate: (a) under any applicable legal and/or regulatory requirements, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) as part of our efforts to keep our Services safe and secure, including to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.
We may share your Personal Information with selected third parties including:
affiliates, business partners, joint marketers, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
advertisers and advertising networks solely to select and serve relevant advertisements to you and others; and
analytics and search engine providers that assist us in the improvement and optimisation of our site.
Your Personal Information may also be disclosed:
consistent with choices that may be available to you, to permit selected third parties to provide you with information about goods or services;
by you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public;
in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our User Agreement and other applicable agreements; or to protect the rights, property, or safety of TransferWise, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
to assist us in conducting or co-operating in investigations of fraud or other illegal activity, or to respond to requests from public and government authorities (including those outside your country of residence), where we believe it is reasonable and appropriate to do so;
to prevent and detect fraud or crime;
in response to a subpoena, warrant, court order, or as otherwise required by law;
to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;
to allow us to pursue available remedies or limit the damages that we may sustain
to recover debt or in relation to your insolvency; and
to develop customer relationships, services and systems.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions in any such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out, we may still send you important administrative messages, from which you cannot opt-out.
Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates, and others. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us. If you follow a link to any of these websites, please note that we are not responsible for the privacy, information or other practices of any of these third parties.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Apple, Google, Microsoft, RIM or any other app developer, app provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact” section below.
If you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may contact us at our Customer Support number.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Information through the Services.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.