Last updated October 5, 2020
Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person or company and can be used to identify that person, including Account Information, Identification Information, Financial Information and KYC Information, each as described below. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.
The Information we Collect
When you visit the website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use our Service.
We may also collect the below information with you.
“Account Information” meaning text-enabled cellular/wireless telephone number, machine or mobile device ID.
“Identification Information” meaning your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
Device Information – We also may obtain information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, geo-location, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
“Financial Information” meaning bank account and routing numbers and credit cards linked to your Wyre account. Please refer to our GLBA notice for more information on how we use your Financial Information.
Know Your Customer Information (“KYC Information”) meaning information collected through a W-9 and other Identification Information.
We are committed to providing safe, secure and all-around great Services. Therefore, before permitting you to use our Services, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain personal information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using our Services, we collect information about your account transactions and trust relationships and we may collect information about your computer or other access device for fraud prevention and other similar purposes. We may also collect personal information related to your contact with our customer support team or store results when you respond to a survey.
We do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
When you access our website, we, or companies we hire to track how our website is used, may place small data files called cookies or pixel tags on your computer or other device. For example, we send a "session cookie" to your computer any time you log in to your Wyre account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don't need to ask you for your password on each page. We use these technologies to recognize you as a Wyre customer, customize content and advertising, measure promotional effectiveness, and collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety. The use of these cookies are optional.
Users are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website.
How we Protect and Store Personal Information
We store and process your personal information using third-party servers located in secure data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. We are PCI-compliant and ensure that all payment details are encrypted at rest [and in transit]. By using Wyre, you are consenting to have your personal information stored, transferred and processed in the United States. Whenever we transfer your personal information out of the European Union, we ensure that it is all securely stored and processed in Amazon Web Services.
Wyre offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet with adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available upon request to email@example.com.
We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well, including never sharing your password with anyone.
If Wyre learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using our services, you agree that Wyre may communicate with you electronically. Wyre may post a notice on the Website if a security breach occurs. Wyre may also send you an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.
How we use the Personal Information we Collect
Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience.
We may use your personal information to:
provide the services and customer support you request;
process transactions and send notices about your transactions or your network activity;
resolve disputes, collect fees, and troubleshoot problems;
prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
compare information for accuracy and verify it with third parties; and
perform other duties as required by law.
We only store personal information as long as it is needed for the purpose for which it was collected. We will keep Account Information only as long as you are registered as a user. However, after you delete your account, we may process such personal information as is necessary for us to fulfill an agreement with you, or such personal information as we are required to keep by law.
In order for us to provide our Service and for the purposes described in this policy, we will keep any Financial Information for 5-years.
How we Share Personal Information with other Wyre Users
To process your payments on Wyre, we need to share some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users who you transact with on or through Wyre. Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through Wyre, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.
How we Share Personal Information with other Parties
Wyre does not share your email address or phone number with third parties for promotional or marketing purposes.
We may share your personal information with:
Financial institutions with which we partner;
Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order or similar legal procedure, when we need to do so to comply with law we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement, or as otherwise required by law;
Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our behalf;
Service providers under contract who help with parts of our business operations such as marketing and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else;
Other third parties with your consent or direction to do so;
We may also use third-party KYC and anti-money laundering tools to verify the identity of users to help combat fraud and improve user experiences.
If you establish a Wyre account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on Wyre's website) will be shared with the owner of the third party website or application and your information may be subject to their privacy policies. Your Rights and Choices as it relates to your Personal Information
You have the right to ask us not to process your personal information where we process it on the basis of your legitimate interests. You also can review and update your personal information at any time by logging into your sendwyre.com account. You should promptly update your personal information if it changes or is inaccurate.
You can delete your account by emailing firstname.lastname@example.org. When you request for us to delete your account for the Service, your personal information will be permanently deleted from our servers and access to your account will be disabled. In addition, you may opt-out of providing personal information via the mobile application at any time by uninstalling the mobile application using the standard uninstall process available on your mobile device or via the mobile application marketplace or store. We may retain your personal information in accordance with our retention policy and to the extent required to comply with (or we deem it reasonable in light of) any laws or regulations.
You have the right to receive confirmation on whether or not we process personal information concerning you, and in such cases get access to such personal information and also information regarding the personal information and how we process it.
You can request a copy of your personal information which we hold, relating to you and that you have provided us, in a commonly used electronic format (in Europe this is known as a subject access request). If you would like a copy of some or all of it, please contact us and let us know the information you want a copy of, including any account or reference numbers, if you have them. Any subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.
You can require us to correct any mistakes in your information which we hold without charge or undue delay. Taking into account the purposes of the processing, you also have the right to have incomplete personal information about you completed. If you would like to do this, please contact us and let us know the information that is incorrect and the information you want it replaced with.
You have the right to withdraw a consent provided by you at any time by contacting us. If your consent is withdrawn, we will no longer process your personal information for the purpose that you had given your consent to. In some circumstances, you have the right to obtain restriction of the processing of your personal information. For example, if you contest the accuracy of the personal information, you can also require that we restrict the processing of your personal information for such a period that enables us to verify the accuracy of the personal information. You have the right to object to processing of your personal information that is based on our legitimate interests. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
You may always contact Wyre at email@example.com and our data protection officer at 10 John Street, London, WC1N 2EB, United Kingdom, attn.: Javier Caceres if you have any questions or comments regarding our processing of your personal information. You also have the right to complain about the processing of your personal information by lodging a complaint to the relevant data protection authority.
California Residents - Your California Privacy Rights:
California's Shine the Light Law: We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you first agree to such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us.
Do Not Track: Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/ .
California Consumer Privacy Act (CCPA): This part serves as a privacy notice for California residents and applies solely to residents of California. Any terms defined in the CCPA have the same meaning when used in this part. Note that provision of this CCPA notice is not an admission on our part that we are a “business” within the meaning of the CCPA, and nothing in this policy may be construed as such an admission.
Personal Information We Collect
We collect certain “Personal Information” as defined by the CCPA and as listed in Section II and have done so within the last 12 months.
Personal Information does not include: (a) publically available information from government records; or (b) de-identified information or aggregate consumer information.
We obtain the categories of Personal Information listed in Section II from the following categories of sources:
Directly from you
Indirectly when you use our Services (e.g., coolies when using our website)
From any other sources listed in this policy.
Our use of Personal Information
We may use and have disclosed the Personal Information we collect for the purposes detailed in Sections V, VI and VII. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes as those set out in these sections without providing you notice.
We do not sell Personal Information as the term “sell” is defined in the CCPA.
Sarhing Personal Information
We may disclose any or all of the categories above of your Personal Information to third parties for a business purpose, as set forth in this policy, and we have done so in the last 12 months.
Your Rights and Choices
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (as described below), we will disclose to you (unless an exception applies):
the categories of Personal Information we collected about you;
the categories of sources for the Personal Information we collected about you;
our business or commercial purpose for collecting that Personal Information;
the categories of third parties with whom we share that Personal Information;
the specific pieces of Personal Information we collected about you (also called a Personal Information portability request);
if we disclosed your Personal Information for a business purpose, a list of disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained;
We do not provide these Personal Information access and portability rights for B2B Personal Information to the extent such an exception remains in effect under the CCPA.
Deletion Request Rights
California residents have the right under the CCPA to request that we delete any of their Personal Information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request (see below), we will delete (and direct our service providers to delete) relevant Personal Information from our records, unless an exception applies (such as the B2B exception referenced above).
We may deny California residents’ deletion request if doing so is permitted or required by applicable law, or if retaining the Personal Information is necessary for us or our service provider(s) to:
complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with the requesting individual, or otherwise perform our contract with a requesting individual;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
debug products to identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another to exercise their free speech rights, or exercise another right provided for by law;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
enable solely internal uses that are reasonably aligned with consumer expectations;
comply with a legal obligation; and
make other internal and lawful uses of that Personal Information that are compatible with the context in which you provided it.
Verifiable Consumer Request
To exercise the access, portability, and deletion rights under the CCPA described above, please submit to us a verifiable consumer request.
Only a California resident may make a verifiable consumer request related to their Personal Information. A California resident may also make a verifiable consumer request on behalf of their minor child.
A verifiable consumer request for Personal Information access or portability can only be made twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify the California resident about whom we collected Personal Information or an authorized representative, and contain sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account on our website. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Personal Information portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the Personal Information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Except as permitted by the CCPA, we will not:
Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
Provide you a different level or quality of goods or services; and
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Links to other Sites
The Website may contain links to other sites. Wyre does not control the information collection of sites that can be reached through links from the website. We encourage our users to be aware when they are leaving our site and to read the privacy statements of each website that collects personal information.
How to Contact us
If you have questions or concerns regarding this policy, or any feedback that you would like us to consider, please email us at firstname.lastname@example.org.