Last Updated: 1 September 2022
Version Number: 1.5
Please read this Policy carefully, as it becomes legally binding when you use our Services. For the full definition of the capitalised words here, check our Customer Agreement. We take privacy and protection of your data very 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.
1. Data Controller
The Data Controller for the collection, processing and use of personal data is Wise Payments Limited, (“Wise”, “us”, “we”, “our'') an international business with headquarters on the 6th Floor of The Tea Building, 56 Shoreditch High Street, London E1 6JJ. Our registration number with the Information Commissioner’s Office UK (ICO) is Z2976089. If you have any questions about how we protect or use your data, please email us at firstname.lastname@example.org.
2. Data we collect about you
Personal data, or personal information, means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. We will collect and process personal data about you as follows:
- 2.1 Information you give us.
- You may give us information about yourself when you sign up to use our Services, e.g. when you provide us with personal details including your name and email address. This also includes information you provide through your continued use of our Services, your participation in discussion boards or other social media functions on our Website or App, through entering a competition, promotion or survey, and by reporting problems with our Services. Additional information you give us for security, identification and verification purposes may include your 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.
- The content of your communications with us, which we collect via telephone call recordings, online chat, emails, direct messaging and other means.
- In some cases, including when you send or receive high value or high volume transactions, or where we need to comply with anti-money laundering regulations, we may also need more commercial or identification information from you.
- In providing the personal data of any individuals other than yourself, including payment beneficiaries or if you are recommending a friend, or providing information on directors or owners of a company, or giving us access to your contacts list, you confirm that you have obtained consent from such individuals to disclose their personal data to us or are otherwise entitled to provide this information to us. You also confirm that you have their consent to our collection, use and disclosure of such personal data, for the purposes set out in this Policy.
- Please ensure that your personal data is current, complete and accurate by logging onto your account and updating it whenever necessary.
- 2.2 Information we collect about you.
With regard to your use of our Services, we may automatically collect the following information:
- details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates;
- technical information, including the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- 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 (including scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support service.
- 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. These may include:
- the banks you use to transfer money to us will provide us with your basic personal information, including your name and address, as well as your financial information, including your bank account details;
- business partners may provide us with your name and address, as well as financial information, including card payment information;
- advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, including confirming how you found our website;
- credit reference agencies do not provide us with any personal information about yourself, but we may use them to corroborate the information you have provided to us;
- fraud prevention agencies may provide information that helps us to combat fraud.
- 2.5 Sensitive data. We process a limited amount of sensitive data when we carry out verification of identity documents that contain biometric data, where we are relying on the substantial public interest condition in Article 9(2)(g) of the GDPR and condition 14 ‘Preventing fraud’ in Part 2 of Schedule 1 of the Data Protection Act 2018. When you use biometric data, including your fingerprint, to unlock the Wise app on your device or to provide authorisation, this biometric information is kept on your device and is not sent to Wise.
- 2.6 Children's data. Our products and services are directed at adults aged 18 years and over, and not intended for children. We do not knowingly collect data from this age group. Our verification process prevents Wise from collecting this data. Any data collected from a child before their age is determined will be deleted.
3. How we protect your personal information
- 3.1 We take the safeguarding of your information very seriously. The transmission of information via the internet is not completely secure. Although we 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 use strict procedures and security features to ensure it stays secure, including:
- Communication over the Internet between you and Wise systems is encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in.
- We update and patch our servers in a timely manner.
- We run a Responsible Disclosure and bug bounty program to identify any security issues in Wise services.
- Our technical security team proactively monitors for abnormal and malicious activity in our servers and services.
- We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards (including obligations to protect any information and applying appropriate measures for the use and transfer of information).
- When information you’ve given us is not in active use, it is encrypted at rest.This means it’s unreadable without the decryption key.
You can find out more from our security page.
- 3.2 We are regularly audited to confirm we remain compliant with our security certifications, including SOC 2 and PCI-DSS. As part of these audits, our security is validated by external auditors.
- 3.3 We restrict access to your personal information to those employees of Wise who have a business reason for knowing such information and third party service providers’ processing data on our behalf. All Wise employees who have access to your personal data are required to adhere to this Policy and all third-party service providers are requested by Wise to ensure appropriate safeguards are in place (including non-disclosure agreements). In addition, contracts are in place with such third-party service providers acting as data processors for Wise that have access to your personal data, to ensure that the level of security required in your jurisdiction is in place, and that your personal data is processed only as instructed by Wise.
- 3.4 We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, technical and organisational safeguards that comply with applicable laws and regulations to protect your personal information from unauthorised access.
4. Ways we use your information
- 4.1 Lawful basis:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where you have given us your consent to process your data;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we have a legal obligation to process your personal data to comply with laws, regulations or court orders;
- Where it is necessary to fulfil our obligations under a contract with you;
- Where it is necessary to protect the vital interests of yourself or other individuals.
- 4.2 Purposes for which we will use your personal data: the ways we plan to use your personal data are described below, including which of the legal bases we rely on to do so in the UK and the EU. We have also identified what our legitimate interests are where appropriate.
- to carry out our obligations relating to your contract with us for provision of payments services and multi-currency accounts - Lawful basis for processing, including basis of legitimate interest: Necessary to fulfil our obligations under a contract
- to provide you with information, products and services - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to keep our records up-to-date, decide which of our products and services may be of interest to you and to tell you about them) and where you’ve consented for us to process your personal data in a certain way.
- to comply with any applicable legal and/or regulatory requirements, including to respond to requests from public and government authorities, including public and government authorities outside your country of residence upon demonstration of lawful authority - Lawful basis for processing, including basis of legitimate interest: Legal obligation, Necessary to fulfil our obligations under a contract and Legitimate interest (to be efficient about how we meet our legal obligations and to comply with regulations that apply to us).
- to prevent and detect crimes, including fraud and financial crime - Lawful basis for processing, including basis of legitimate interest: Legal obligation and Legitimate interest (to detect and prevent criminal activity in connection with our Services and improve how we manage instances of suspected financial crime).
- to notify you about changes to our Services and send you other administrative information - Lawful basis for processing, including basis of legitimate interest: Legal obligation, Legitimate interest (to provide you with a good customer service and keep you up-to-date with new developments) and Necessary to fulfil our obligations under a contract.
- as part of our efforts to keep our Services safe and secure - Lawful basis for processing, including basis of legitimate interest: Legal obligation, Legitimate interest (protecting our customers and ourselves from loss or harm) and Necessary to fulfil our obligations under a contract.
- to administer our Services and for internal operational, planning, audit, troubleshooting, data analysis, testing, research, statistical and survey purposes - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to keep our records up to date, efficiently fulfil our legal and contractual duties, carry out our administrative operations, and develop new and existing products and services).
- to undertake system or product development, improve our Services and to ensure that they are presented in the most effective manner - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to develop existing and new products and services and to efficiently meet our legal and contractual obligations).
- to allow other Wise customers to request or send money to you through our services when providing information that matches your phone number or email address - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to provide an efficient and innovative service to our customers) and necessary to fulfil our obligations under a contract.
- to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to market our products and services in the most efficient manner) and where you’ve consented for us to process your personal data in a certain way.
- to allow you to participate in interactive features of our Services, when you choose to do so - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to provide an efficient and innovative service to our customers) and where you’ve consented for us to process your personal data in a certain way.
- to provide you with information about other similar goods and services we offer - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to market our products and services) and where you’ve consented for us to process your personal data in a certain way.
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you - Lawful basis for processing, including basis of legitimate interest: Where you’ve consented for us to process your personal data in a certain way.
- to take steps to recover amounts owed to us and to allow us to pursue available remedies or limit damages that we may sustain - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to protect our assets).
- to enforce our Customer Agreement with you - Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to protect our assets).
- on rare occasions, to help safeguard our customers, employees or other individuals by notifying the emergency services - Lawful basis for processing, including basis of legitimate interest: Vital interest.
5. Disclosure of your personal data
- 5.1 We may share your personal data with third parties including:
- affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
- advertisers and advertising networks to select and serve relevant adverts to you and others with your consent;
- analytics and search engine providers that assist us in the improvement and optimisation of our site;
- our group entities and subsidiaries; and
- limited information is sent to payment beneficiaries when you initiate a payment transaction.
- 5.2 We may disclose your personal information to third parties:
- including affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
- in the event that we sell or any business or assets or combine with another organisation, in which case we may disclose your personal data to the prospective buyer of such business or assets or prospective organisation with which our business or assets may be combined;
- 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 Wise, our customers, our employees 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 with investigations of fraud or other illegal activity 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, properly constituted police request or as otherwise required by law;
- to assess financial and insurance risks;
- to recover debt or in relation to your insolvency; and
- to develop customer relationships, services and systems.
- 5.3 We do not have a list of all third parties we share your data with, as this would be 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 email@example.com.
6. Sharing and storing your personal data
- 6.1 We may transfer your data to and and store it in countries outside the UK and European Economic Area ("EEA") which do not offer an equivalent level of protection to your country. It may also be processed by staff operating outside the UK and EEA. Such staff may be engaged in activities that include the fulfilment of your payment order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
- 6.2 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 that are based outside of the UK and EEA. In these cases, we ensure that appropriate safeguards, including Standard Contractual Clauses, are in place.
7. Profiling and automated decision making
- 7.1 We may use some elements of your data to customise our Services and the information we provide to you, and to address your needs, including your country of residence 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 use pseudonymised data wherever possible. This activity has no legal effect on you.
- 7.2 We have no wholly automated decision making processes (ADM) which have a legal impact on you. If you feel that an ADM process may have had an impact on you, contact us at the details below.
9. Data Retention
- 9.1 We will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it. As a regulated financial institution, Wise is required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need to know basis, and we’ll only access or process it if absolutely necessary.
- 9.2 We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate. We do this automatically, so you don’t need to contact us to ask us to delete your data.
- 9.3 Learn more about the retention periods for your data
10. Your rights
- 10.1 Subject to applicable laws, you may have certain rights regarding the information we hold about you. Your rights can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. You may have the right to:
- Request a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.
- Ask us to delete personal information where there is no good reason for us to continue to process it. You may also have the right to ask us to delete your personal data where (i) you have successfully exercised your right to object to processing (see below), (ii) where we may have processed your information unlawfully or (iii) where we are required to delete your personal data to comply with local law. We may not always be able to comply with your deletion request for specific legal reasons which will be notified to you, if applicable, in our response to your request, including financial regulations that may require us to hold your personal data for a period after the closure of your account;
- Withdraw your consent for us to process data, where our lawful basis for processing is based on that consent. Note that withdrawal of consent does not affect the lawfulness of processing which may have taken place prior to withdrawal of consent. If you withdraw your consent, we may not be able to provide certain products or services to you;
- Request us to cease direct marketing to you, by contacting us or adjusting your notification preferences in the settings section of your account;
- Where we use wholly automated decision making-processes, request that we provide information about the decision-making methodology and ask us to verify that an automated decision that results in a legal impact on you has been made correctly. We may reject the request, as permitted by applicable law, including when providing the information would result in a disclosure of a trade secret or would interfere with the prevention or detection of fraud or other crime. However, generally in these circumstances we will verify that the algorithm and source data are functioning as anticipated without error or bias or if required by law to adjust the processing.
- Object to any processing based on the legitimate interests ground when there is something about your particular situation where you feel processing on this ground impacts your fundamental rights and freedoms.
- Ask us to suspend the processing of your personal data in the following situations: (i) if you want us to determine the data's accuracy; (ii) where our processing of the data is unlawful but you do not want us to delete it at this time; (iii) where you wish us to retain the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or (iv) you have objected to us using your data but we need to confirm whether or not we have over-riding legitimate grounds to continue using it.
- Request the transfer of your personal data to a third party or yourself. We will provide you or your chosen third party with the personal data you provided to us in a structured, commonly used, machine-readable format. This right applies only to information where we used the information to perform a contract with you or where you initially consented for us to use it.
- 10.2 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (including the prevention or detection of crime) and our interests (including the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
11. Third-party links
- 11.1 Our Services may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility for them, so if you follow a link, check these policies before you submit any personal data to these websites.
- 12.1 To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Policy at any time without notice by posting a revised version on this website. To stay up to date on any changes, check back periodically.
- 13.1 Please send any questions, comments or requests regarding this Policy to our privacy team at firstname.lastname@example.org. You can also write to us at the following address: TransferWise Ltd, 6th Floor of The Tea Building, 56 Shoreditch High Street, London E1 6JJ.
- 13.2 If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws. In the United Kingdom this is the Information Commissioner’s Office at www.ico.org.uk.