Transferwise Privacy Policy (USA)

Last Updated: December 31, 2019

This Privacy Policy contains an overview about the collection, use and disclosure your personal data. In case the information covers only one of our services we will explicitly point this out to you. Please check the Customer Agreement for the meaning of defined words (those with capital letters).

Please read this Privacy Policy carefully as it applies when you use our Services or visit our Website or use our App. We take privacy and protection of data seriously and are committed to handling the personal information of those we engage with, whether customers, suppliers or colleagues, responsibly and in a way that meets the legal requirements of the countries in which we operate.

Please note that 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.

  1. Who we are

    TransferWise Inc. (“TransferWise”, “us”, “we”, “our'') is responsible for the collection, use and disclosure of your personal information. If you have any questions about how we protect or use your data, please email us at privacy@transferwise.com.

  2. Data we collect about you

    We will collect the following data about you:

    1. Information you give us:

      We will collect the following data about you:

      1. You may give us information, including personal information, about yourself when you sign up to use our Services, e.g. your name and email address. This also includes information you provide through your continued use of 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.
      2. 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.
      3. In providing the personal data of any individual (other than yourself) that for example may receive payments from us as part of your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy.
    2. Information we collect about you. With regard to your use of our Services, we may automatically collect the following information, some of which may be or include personal information:

      1. details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;
      2. 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;
      3. 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.
    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:

      1. the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
      2. business partners may provide us with your name and address, as well as financial information, such as card payment information;
      3. advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website;
      4. credit reference agencies do not provide us with any personal information about yourself but may be used to corroborate the information you have provided to us.
    4. Information from social media networks. If you log in to our Services using your social media account (for example, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy.

    5. Children’s information

      Our products and services are directed at adults 18 years and over and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents TransferWise collecting such data. If any information is collected from a child without verification of parental consent, it will be deleted.

  3. How do we protect your information

    1. We use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transaction information will be encrypted using Transport Layer Security technology.
    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 information, we cannot guarantee the security of your information 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.

      We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information.

  4. Uses made of the information

    1. We use your information in the following ways:
      1. to carry out our obligations relating to your contract with us and to provide you with the information, products and services;
      2. to comply with any applicable legal and/or regulatory requirements including laws outside of your country of residence or to comply with any legal process;
      3. to notify you about changes to our Services;
      4. 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;
      5. as part of our efforts to keep our Services safe and secure;
      6. to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
      7. to improve our Services and to ensure that they are presented in the most effective manner;
      8. to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

      9. to allow you to participate in interactive features of our Services, when you choose to do so;
      10. to allow us to pursue available remedies or limit the damages that we may sustain and to enforce our terms and conditions
      11. so that we can provide you with information regarding our public policy advocacy efforts.
      12. to provide you with information about other similar goods and services we offer;

      13. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or

      14. to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
  5. Disclosure of your information

    1. We may share your information with selected third parties including:
      1. affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
      2. advertisers and advertising networks solely to select and serve relevant adverts to you and others;
      3. analytics and search engine providers that assist us in the improvement and optimisation of our site; and
      4. our group entities or subsidiaries - which can be found by clicking here
    2. We may disclose your personal information to third parties:

      1. affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
      2. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
      3. 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 Customer 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;
      4. to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
      5. to prevent and detect fraud or crime;
      6. in response to a subpoena, warrant, court order, or as otherwise required by law;
      7. to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;
      8. to allow us to pursue available remedies or limit the damages that we may sustain
      9. to recover debt or in relation to your insolvency; and
      10. to develop customer relationships, services and systems.
    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 dependent 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 privacy@transferwise.com.

  6. Sharing and storing your personal data

    1. The data that we collect from you may be transferred to, and stored at, a destination outside the United States. It may also be used by staff operating outside the US who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
  7. Cookies

    1. We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with the best experience. It also enables us the ability to improve our services, for detailed information on cookies and other technologies we use and the purposes for which we use them see our Cookie Policy.
  8. Retention of your information

    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, see your rights below. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
    2. We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.
    3. Retention periods defined for the storage of your data can be found by clicking here.
  9. California related rights

    1. California Consumer Privacy Act Notice

      In this notice, we are addressing the disclosure requirements under the California Consumer Privacy Act of 2018 (the CCPA) for California residents. This notice should be read together with our Privacy Statement and applies to all California residents who visit our Website or use our Services.

      Personal Data Collection and Purposes of Use: We collect, use and share the personal data of California residents as described above.

    2. California Consumer Privacy Act

      Now that you know how we collect, use and share your personal information, the CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. In addition, the California Shine the Light law (CA Civ. Code § 1798.83) requires us to provide California residents with, upon their request, the names and addresses of third parties who have received personal information and the categories of personal information shared.

      California residents have the right to request that TransferWise Inc. discloses what personal information TransferWise has collected, used, disclosed, and sold over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the necessary information in a portable and easily accessible format, normally within 45 days of request. You may only make a verifiable consumer request for access or data portability twice in a 12-month period.

      When providing information under the right to know, we will include:

      • The categories of personal information the business collects about the consumer and has disclosed or sold for a business purpose
      • The categories of sources of the consumer’s personal information
      • The business or commercial purpose for collecting and selling the consumer’s personal information
      • The categories of any third parties with whom the business shares the consumer’s personal information or to whom personal information is sold
      • The specific pieces of personal information collected about the consumer

      California residents also have the right to request the deletion of their personal data, subject to certain exceptions, and may not be discriminated against because they exercise their rights under the California Consumer Privacy Act. We may require you to provide additional personal data to verify your identity before we process your request; we may not process your request if we are unable to verify your identity.

      California residents also have the right to opt-out of the sale of personal information. In the preceding twelve (12) months TransferWise has not sold any personal information.

      If you are a California resident and would like to make a request, please submit your request, in writing, to:

      TransferWise Inc.
      Attention: Legal and Compliance Team
      19 West 24th Street, 9th Floor
      New York, NY 10010
      Or by email to privacy@transferwise.com.

      You can also submit by these methods your questions or express concerns about TransferWise’s privacy policies and practices.

  10. Third-party links

    1. 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. Changes to our privacy policy

    1. To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the website and update the “Last Updated” date. To stay up to date on any changes, please check back periodically. Your use of our services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at privacy@transferwise.com..
  12. Contact

    1. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our global privacy team at the following email address – privacy@transferwise.com, or you can write to us at the following address:

      TransferWise Inc.
      Attention: Legal and Compliance Team
      19 West 24th Street, 9th Floor
      New York, NY 10010

Facts

WHAT DOES TRANSFERWISE, INC. DO
 WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you 
how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  • Social Security number and checking account information
  • account balances and payment history
  • transaction history and wire transfer instructions
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons TransferWise, Inc. chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does TransferWise, Inc. share? Can you limit this sharing?
For our everyday business purposes—
such as to process your transactions, maintain 
your account(s), respond to court orders and legal investigations, or report to credit bureaus
Yes No
For our marketing purposes—
to offer our products and services to you
Yes No
For joint marketing with other financial companies
Yes No
For our affiliates’ everyday business purposes—information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes—information about your creditworthiness
No We don’t share
For nonaffiliates to market to you
No We don’t share
Questions? Call (888) 908-3833

What we do

How does TransferWise, Inc. protect my personal information?
To protect your personal information from unauthorized access 
and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files 
and buildings.
How does TransferWise, Inc. collect my personal information?
We collect your personal information, for example, when you
  • open an account or give us your contact information
  • tell us who receives the money or tell us where to send the money
  • make a wire transfer
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • tell us who receives the money or tell us where to send the money
  • make a wire transfer
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Definitions
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Our affiliates include companies with a TransferWise name; financial companies such as TransferWise Limited and TransferWise Canada Inc.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • ransferWise Inc. does not share with nonaffiliates so they can market to you
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
  • Our joint marketing partners can include banks
Other Important Information

For California residents:

We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing with our affiliates to the extent required by California law.

See our Privacy Policy for further information about the rights provided to California Residents with respect to personal data we may collect about them.

For Vermont residents:
We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness with our affiliates, other than as permitted by Vermont law, unless you authorize us to make those disclosures.