In this Policy, we use the terms "we", "us", and "our" (and other similar terms) to refer to Wirecard, and "you" and "your" (and other similar terms) to refer to our customers, contacts, suppliers, job applicants and website visitors.
This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference. When you deal with Wirecard we will assume you agree to the uses of your Personal Information described in this Policy unless you tell us otherwise in writing.
For the purpose of the Data Protection Act 1998, the data controller is Wirecard Card Solutions Limited of Grainger Chambers, 3-5 Hood Street, Newcastle Upon Tyne, United Kingdom NE1 6JQ.
How to contact us
If you have any questions about how we collect, store and use Personal Information, then please contact us using the details provided below:
- Write to us at: The Data Protection Officer, Wirecard Card Solutions Limited, Grainger Chambers, 3-5 Hood Street, Newcastle Upon Tyne, United Kingdom, NE1 6JQ]; or
E-mail us at: firstname.lastname@example.org
The Personal Information that we may collect from you
From initial contact through to providing you with our services or working together in other ways, we may collect Personal Information about you. In particular, we may collect and process the following data about you:
- Information that you provide by filling in forms on our site. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our site;
- If you contact us, we may keep a record of that correspondence;
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- Details of transactions you carry out through our site or via use of our services and of the fulfilment of your transaction requests;
- Details of your visits to our site including and the resources that you access;
If you are a customer (or prospective customer) of Wirecard: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. We may also hold confidential details about any matter on which you choose to engage us, as well as your bank account and/or other payment details for the purpose of paying our charges. In addition, we may also hold the information described in the "If you are a contact of Wirecard" bullet below.
We will obtain personal information from you and your communications with us via email, the internet, telephone exchanges and other interactions or via third parties, including employers, fraud prevention and credit reference agencies or other organisations involved in the support or provision of your prepaid card and the associated services. We will also obtain Personal Information as a result of what we learn from the way you use and manage your prepaid card and associated account and services, from the transactions we support and from the payments you make.
If you are a supplier (or prospective supplier) to Wirecard: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent. We may also collect your Personal Information through materials you may provide to us in relation to the services you supply to us, as well as your bank account and/or other payment details for the purpose of paying your fees. In addition, we may also hold the information described in the "If you are a contact of Wirecard" bullet below.
If you are a contact of Wirecard: We may collect, store and use your contact details, copies of any e-mail, postal or other correspondence between you and us, and recordings of any voicemails that you choose to leave. We may also hold details of any contact preferences that you specify, such as requests to subscribe to publications that we may circulate from time to time, to receive news about any events we are organising or participating in, or to receive information about Wirecard and the services we provide.
If you are a job applicant: We may collect, store and use your contact details, copies of your job application, curriculum vitae and covering letter, as well as any references provided or obtained, for the purposes of processing your application and for general recruitment and selection purposes.
If you are a website visitor: We may collect, store and use certain, limited information relating to your use of the Wirecard website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from Wirecard (as described in the "If you are a contact of Wirecard" bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in our Cookies Policy.
On occasion we may collect additional Personal Information for a specific purpose. In such circumstances we may provide specific additional notice about that processing and purpose at the time those data are collected and any disclosures made and information given at the point of such collection will also form a part of this Policy.
How we use your Personal Information
The ways in which Wirecard may use your Personal Information necessarily depends on the relationship you have with us. Examples of the ways in which we use the Personal Information that we collect include:
For contact and communication purposes: We may use your contact information and preferences to send you publications that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about Wirecard and the services that we provide. We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications where you have told us you do not wish to receive these. You can specify your contact preferences when registering online to receive communications from us (for example, through the Wirecard website) or by subsequently advising us of your contact preferences using the contact details provided above.
To provide our services to our customers: We may also use Personal Information to provide our services to our customers, for example, opening, administering and running customer prepaid card accounts (including using mobile phone numbers and email addresses to provide balance updates and transaction alerts in the manner requested by our customers) and dealing with any customer enquiries. In addition, if we suspect that we have been given false or inaccurate information, we may record our suspicion together with any other relevant information.
Customers must not give us Personal Information about someone else (such alternative named contacts) without first getting their consent for it to be used and disclosed for such use. When customers provide such third party information we will assume they have consented, although we may still ask for confirmation.
Please note that we will assume, unless our customers instruct us otherwise in writing, that we may use and disclose their Personal Information in such manner as we believe is reasonably necessary to provide our services to them (including as described in this Policy and as otherwise agreed between us).
To receive services from our suppliers: We will use our suppliers Personal Information to receive their services from them. Please note that we will assume, unless our suppliers instruct us otherwise in writing, that we may use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from them.
To collect our charges or costs in connection with other legal enforcement: We will use Personal Information to agree payment arrangements with you, and to collect our fees and costs owing to us in connection with legal enforcement.
To make payments to our suppliers: We will use our suppliers Personal Information to agree payment arrangements with our suppliers, and to make payments to them.
For recruitment and selection purposes: If you apply for a position with Wirecard, we will use your Personal Information to process your job application and for general recruitment and selection purposes. If you are successfully recruited, the Personal Information you provide will be stored on your personnel file.
For website analytics purposes: We may collect, store and use certain, limited information relating to your use of the Wirecard website for the purposes of better understanding the types of visitors who browse our website and improving our website offering. Other than information you choose to submit voluntarily to receive communications from Wirecard (as described in the "If you are a contact of Wirecard" bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in our Cookies Policy.
Who else may have access to your Personal Information
On occasion, Wirecard may need to share your Personal Information with third parties. Where you supply us with Personal Information as a customer, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy and in our terms and conditions), or as is required under applicable law.
Specific circumstances where we may pass your Personal Information to third parties might include:
Credit-checking agencies: If you are a customer, we may check all personal information given by you with credit reference or fraud prevention agencies and other organisations and we may perform a search of your credit file in order to verify your identity. The agencies may keep a record of your information and the searches made (even if ultimately any application is unsuccessful or does not proceed).
Events: We may need to pass on your Personal Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose.
Business partners, service providers and other affiliated third parties: To enable us to provide our services to you, we may need to share your Personal Information with our business partners, service companies and/or service providers, for example, we may inform our partners involved in processing the transactions and/or supplying the services associated with prepaid cards when customers start using their prepaid cards, however, we will not disclose details of any loads, withdrawals or transactions that are made.
We may also disclose Personal Information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. Personal Information may also be transferred confidentially to Card Schemes, such as MasterCard and Card bureaus so that we can provide prepaid card and associated services to our customers.
We will seek your express consent before third parties contact you by email or mobile phone about any offers they believe will interest you.
Wirecard offices: We may share your Personal Information with Wirecard offices in other countries where we believe this is reasonably necessary to provide you with our services. Specifically, our services use and rely on the back-office processing and storage services of our German parent company Wirecard AG and its systems and servers based in Germany. In order to support our services and associated transactions your Personal Information is shared with Wirecard AG but processed in accordance with the terms and security measures outlined in this Policy.
Disclosures required by law or regulation: In certain circumstances, please note that we may be required to disclose Personal Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
Publicity: In keeping with market practice, unless you advise us in writing to the contrary, you consent to the disclosure of our involvement as your service provider for the purposes of publicising our services. We may also provide a general description of the work we've done for you, or a more detailed description if this information is already in the public domain or you expressly consent to this.
Other: We may disclose Personal Information in the event that we sell or buy any business or assets, in which case we may disclose Personal Information to the prospective seller or buyer of such business or assets. We may also disclose Personal Information if Wirecard or substantially all of its assets is acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
Monitoring for quality assurance and training
Wirecard strives to ensure that the services it delivers to its customers are of the highest possible standard. With this aim in mind, it may sometimes be necessary for us to monitor telephone and e-mail communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law. We will only ever conduct communications monitoring in compliance with applicable law, and will at all times continue to protect the privacy of your communications in accordance with this Policy.
International transfers of Personal Information (including to outsourced service providers)
As described above, from time to time, Wirecard may need to transfer your Personal Information to business partners, service providers and other Wirecard offices that are located in territories outside of the European Economic Area ("EEA").
For example, as well as described above in respect of Wirecard offices in Germany, we may provide customers' prepaid card and associated accounts and services from centres such as the USA and India and we may process payments through other organisations such as banks, payment processors, card networks and payment schemes. In applying for a prepaid card and associated accounts and services from Wirecard you explicitly consent to this.
Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA, although we will ensure that your Personal Information is only ever treated in accordance with this Policy and, if you are a customer, our terms and conditions.
How we look after your Personal Information
We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
If you or others on your behalf give us any Personal Information about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that information to us, and our use of it as explained in this Policy.