Version 1.0 | Effective Date: 29-11-24

At Wirewand Limited (“Wirewand”), we are committed to protecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, and share your information when you use our services, including our website, mobile applications (available on Google Play and App Store), and other related products.

Wirewand’s payment services are provided by Frontier Global Ltd t/a FGC, and their policies also apply to the use of our services. By using Wirewand’s services, you agree to this Privacy Policy and FGC’s privacy practices.

If you have any questions or concerns, you can contact us at privacy@wirewand.com.

1. Data Controller

Wirewand Limited is the primary data controller. As payment services are provided by Frontier Global Ltd, certain processing activities may also be carried out under their responsibility.

Contact Information for Wirewand Limited:

• Registered Address: Suite 1 Cochrane House, Admirals Way, London, England, E14 9UD
• Email: privacy@wirewand.co.uk

Contact Information for Frontier Global Ltd:

• Registered Address: 114 Wellington Street, Leeds, LS1 1BA
• https://www.frontier-pay.com/privacy-policy

2. Information We Collect

2.1 Information You Provide to Us

We collect personal information when you:

• Register for an account on our website or app.
• Use our services (e.g., money transfers, foreign exchange).
• Contact us via email, phone, or in-app support.
• Participate in promotions, surveys, or competitions.

This information may include:

• Full name, date of birth, and contact details (address, email, phone number).
• Identification documents, such as a passport or driving licence.
• Financial data, including transaction history and payment details.
• Profile photos or additional information provided via app features.

2.2 Information Collected Automatically

When you interact with our services, we collect technical data, including:

• IP address and browser type.
• Device information (model, operating system, app version).
• Usage data (e.g., pages visited, session duration, clicks).
• Location data through GPS or IP address.

2.3 Information from Third Parties

We may receive information from:

• Frontier Global Ltd, our payment service provider.
• Credit reference agencies and fraud prevention services.
• Marketing or analytics providers.
• Open Banking and other integrated service providers.

3. How We Use Your Information

We process your information to:

1. Provide and improve our services: Facilitate transactions, manage accounts, and enhance your experience.
2. Comply with legal obligations: Meet anti-money laundering (AML), fraud prevention, and other regulatory requirements.
3. Communicate with you: Send service updates, marketing messages (if consented), and respond to inquiries.
4. Analyse performance: Improve service delivery and user experience through data analysis.

Lawful bases for processing your data include:

• Contractual necessity: To deliver services as outlined in our agreement with you.
• Legitimate interest: To improve our offerings and safeguard our business.
• Legal obligations: To comply with applicable laws and regulations.
• Consent: For activities such as marketing (when required).

4. Sharing Your Information

We may share your personal data with the following parties:

4.1 Service Providers

• Frontier Global Ltd for payment processing and related services.
• Business partners, subcontractors, and suppliers essential to delivering our services.

4.2 Regulatory and Legal Bodies

• Credit reference agencies for identity verification and credit checks.
• Fraud prevention organisations to protect against illegal activities.
• Law enforcement agencies, tax authorities, or regulators when required by law.

4.3 Other Third Parties

• Marketplace partners or Open Banking providers if you choose to integrate their services.
• Organisations with which you request or authorise us to share your information.

We require all third parties to handle your data securely and in accordance with applicable laws.

5. Data Retention

We retain your personal data for six years from the date your relationship with us ends. In certain cases, data may be retained longer if required for legal, regulatory, or legitimate business purposes.

6. Your Rights

Under data protection laws, you have the following rights:

1. Right to Access: Request access to the personal data we hold about you.
2. Right to Rectification: Update or correct inaccurate or incomplete information.
3. Right to Erasure: Request deletion of your data, subject to legal and regulatory requirements.
4. Right to Restrict Processing: Limit how we process your data in certain circumstances.
5. Right to Object: Object to the processing of your data, including for direct marketing.
6. Right to Data Portability: Transfer your data to another service provider.

To exercise any of these rights, please contact us at privacy@wirewand.co.uk. We aim to respond within one calendar month, but complex or multiple requests may take up to three months.

7. International Data Transfers

In some cases, your data may be transferred outside the UK or EEA. If this occurs, we ensure adequate safeguards are in place, such as:

• Standard contractual clauses approved by relevant authorities.
• Compliance with UK and EEA data protection standards.

8. Data Security

We use encryption, firewalls, and regular audits to protect your data against unauthorised access, alteration, or loss. Despite our efforts, no system is entirely secure.

9. Automated Decision-Making and AI

We use automated systems for:

• Fraud detection and AML compliance.
• Credit scoring and account approval processes.

You can request a human review of any automated decision by contacting privacy@wirewand.co.uk.

10. Updates to This Policy

This Privacy Policy may be updated periodically to reflect changes in our services or legal requirements. We will notify you of significant changes via email or app notifications.

11. Complaints

If you believe your data has been mishandled, you can:

• Contact us at privacy@wirewand.co.uk.
• File a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk.

Wirewand Limited
Suite 1 Cochrane House, Admirals Way, London, England, E14 9UD
Email: privacy@wirewand.co.uk