WIREMONEY

At Wiremoney, we pride ourselves on maintaining the highest levels of security, transparency and

integrity in our work, and recognise the importance of protecting and respecting your personal

data.

Overview

To provide you with our services we need to know things about you. We will only collect

information we need to provide you with the services you have requested and will handle your

information with the utmost care. Any information we receive about you will be subject to strict

controls to minimise the risk of misuse – including unauthorised access to, or disclosure of, your

personal data.

This Privacy Policy applies to information that Wiremoney may collect about visitors to our

website (even if you do not become a customer), companies and individuals who register for our

services, and continue using our services, and any other person who contacts us over the telephone

or in writing.

Please read this notice carefully, together with our Terms and Conditions and any other documents

referred to within. For the purposes of this Privacy Policy, the term “personal information” means

any data that can identify you as an individual for example name, address and contact information.

If you would like to know more about any of the terms of this Privacy Policy, please contact us

(information provided below) so that we can help you with any questions or concerns.

What information do we collect? And how do we collect it?

Information you provide to us

To open an account or use Wiremoney services, you will be asked to provide identifying

information about yourself (e.g. name, address, and email address), your company and documents

to verify the information provided.

In order to make payments, you will be asked to provide the information required to facilitate the

payment – e.g. beneficiary information, bank account details and source of funds.

In the course of our business relationship, we may ask for additional evidence in order for us to

comply with our legal obligations – e.g. anti-money laundering regulations. These can include, but

are not limited to, documents required to verify any information provided or evidence of source

of funds.

Information we collect when you use our website or app

Our website uses cookies to provide you with a better experience on our website, for fraud

prevention and to provide internet-based advertisements. For detailed information on the cookies

we use and the purposes for which we use them, please see our full Cookies and Tracking Notice.

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The Wiremoney user community participants will have their sessions recorded to allow us to

capture the feedback to improve our services and help with the development of new products.

This will always be based on your consent, which you can withdraw at any time.

For the detection and prevention of fraud and cyber-crime, we will collect information, including

session, device and IP address to help ascertain the legitimacy of the account login.

Public information

For non-registered users, we may contact you using publicly available information or information

from third parties, which you have consented to being shared, to let you know about products that

could be relevant for your business.

Transactional information

Once your account is fully set up and you begin to transact with us we will collect, process and

store your Wiremoney financial and transactional information. This information includes the

amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank

details.

Information about you that we receive from third parties

To protect ourselves and our customers against fraud, we verify the information you provide with

anti-fraud agencies and electronic identity verification services. In the course of verification, we

receive and process information about you from such services.

Information may also be collected from credit reference agencies.

Communications

All calls are recorded and correspondence retained for the purposes of quality control and training,

as evidence of transactions and to fulfil regulation requirements. Any information you disclose to

us will be held on these recordings.

Individuals who are not registered users of Wiremoney

Connected parties

Wiremoney may collect information about connected parties to a Wiremoney client during the

course of the business relationship from the client to comply with our legal obligations - e.g.

directors or shareholders of a company.

Where customers provide this information, they are required to bring this Privacy Notice to the

attention of the individuals concerned.

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Beneficiaries

Wiremoney will collect information required to be able to send a payment to an individual, who

may not be a Wiremoney client. This will include name and bank account details that are required

by regulations to process the payment.

What do we use your information for?

Registration and administration

We use your information to enable you to register with us. Once you have an account with us we

will use your details to contact you and to reply to any queries or requests. We may use your

information in the administration of your account, which includes us contacting you in order to

update your account details (this assists us with keeping our records as up to date as possible) or

in order to notify you of changes or improvements to our products or services that may affect our

service to you.

Our products and services

We use your information in order to supply our products and services to you and to meet our

contractual obligations to you. Additionally, we may need to notify you of any changes relating to

our products and services.

Prevention and detection of crime

We are subject to strict anti-money laundering and counter-terrorist financing regulations which

requires us to undertake due diligence on our customers. This may include the use of electronic

verification tools. As part of our verification requirements, we may require copies of identification

documents and proof of address. We may require additional documentation and information from

time to time in the course of our business relationship with you to ensure we comply with our

anti-money laundering and counter-terrorist financing obligations.

Direct Marketing

We may use your information to keep you up to date concerning our products and services, tell

you about new products/services or to ask about your experience with us. Further information on

setting your preferences, including opting out, is set out below.

Monitoring

We record all our telephone calls for security and training purposes.

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Who do we share your data with?

Banking Partners

Wiremoney uses various banking partners around the world to ensure your payment can get to

where it needs to go as quickly as possible.

For transparency, verification and legal requirements, we are required to include certain

information on the payment which could include:

- Your name

- Your date of birth

- Your address

- Beneficiary details

- Your national identity reference (e.g. passport)

Service Providers

We may share your information with trusted companies providing services to us under

confidentiality agreements such as Veriff. Veriff provide identity verification services on our

customers. To that extent, it accesses and retains information about our customers for the sole

purpose of providing the services. We may share information about customers such as names,

contact numbers and email addresses with other service providers who carry out some specified

services. These service providers include SendX, SendGrid and Azupay, Flutterwave, and Cloudinary.

These third-party services providers retain the customers and end users’ information for the sole

purpose of providing these services to us.

For purposes of identity verification of our customers and end users, Veriff processes some

personal information namely:

• personal identification documents where information such as name of the customer, sex

of the customer, personal identification code, issuing country, expiration date, document

barcodes (may vary depending on the document) and security features are extracted by

Veriff.

• contact details, such as address, e-mail address, telephone numbers, IP address and, where

necessary, presented document type (e.g. utility bill);

• photos and videos as well as other data, such as face scans and measurements, extracted

from the photos and videos which are used to authenticate the identity of the customer or

compare the customer’s face to identity documents presented. Some of the extracted data

may be considered as biometric data and/or sensitive Personal Data (also special category

of personal data, hereinafter referred to as “sensitive Personal Data”) in certain

jurisdictions;

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In course of rendering payment processing services, Flutterwave processes the following

transactional data of the customers and end-users:

• Personal identification information such as full name, email address and phone number.

• Banking information and sometimes customer's payment details/bank information.

As part of the features available on the Wiremoney platform, customer’s profile images are

uploaded to Cloudinary. The latter also retain the profile images in order to provide its services to

Wiremoney.

These companies do not have any rights to market other services with you.

Wiremoney performs due diligence to ensure third parties are compliant with applicable legal and

contractual requirements.

Also, we may share your information with any person acting on your behalf provided that you

have given us the permission to do so.

Regulators and Law enforcement

As part of the regulatory requirements for our business, we share your information with

AUSTRAC (Australian Transaction Reports and Analysis Centre) for purposes of fulfilling our

obligation by submitting periodic reports on our transactions to the body.

We may need to pass necessary information on to Governmental departments, regulatory bodies,

law enforcement/tax/customs agencies, courts of law or other third parties where we are legally

compelled to do so.

We will never sell any personal data that we hold about you.

How long do we keep your personal information for?

Wiremoney will only retain your information for as long as is necessary for providing our service

to you and will not hold or process your information for any longer than we are legally required

to. The criteria used to determine the appropriate retention includes:

- Regulatory requirements Wiremoney is subject to

- Whether a legal claim could be brought against Wiremoney

- Necessity of information to provide our service to our customers

- The legal basis for processing your information – e.g. consent

Information about connected parties and beneficiaries, which may not belong to a Wiremoney

client, are stored for a period to comply with applicable legal requirements.

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Communications

We communicate with you on a regular basis via email and phone to provide excellent customer

service and fulfil requests.

Additionally, we use your email address, phone number and postal address to:

- Provide notification as part of the on-boarding and trading lifecycle

- Send you important changes to our products and services

- Send notices and disclosures required by law

Due to the service-orientated nature of these communications, you cannot opt out to receiving

these.

Marketing

Wiremoney would like to keep you up to date concerning our products and services.

Once you are a client of Wiremoney, we may use your information to provide product information,

and rate and market updates that are relevant to you and/or your company.

We may also use your information (whether you are a registered Wiremoney user or a visitor to

our website) to keep you up to date on general products, market updates or rate movements.

If you change your mind on which communications you would like to receive or how you would

like to receive them or you decide that you do not wish to receive these types of communications,

you can unsubscribe at any time by:

- emailing privacy@wiremoney.com ;

- clicking the link at the bottom of any email that you receive.

You will not miss any service we provide by not choosing to receive marketing from us and you

can change your mind whenever you like as often as you like.

What are your rights?

We recognise and support the rights outlined below. In some countries some or all of these are

legal requirements, in others they are not, but we will endeavour to comply with any request

relating to the below regardless in those jurisdictions. If you would like to exercise any of the below

rights then please contact the Data Protection Manager (privacy@wiremoney.com ) and we will

respond to your query.

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We will require you to provide proof of identity and to provide sufficient information to allow us

to locate relevant information and in order to verify that the person making the request is the

account holder or acting with their permission.

Non-registered users (e.g. website users, connected parties and beneficiaries of payments) have the

same rights as any registered user and can contact Wiremoney to request these.

For more information about your rights, please have a look at your local data protection regulator’s

website.

To ask for information that Wiremoney holds about you to be corrected

If you notice any of the information on your account is incorrect, you can contact us and we will

make any necessary changes, subject to verification of the information.

To ask us to erase your information if we no longer have a reason to hold it

Wiremoney will retain your information only for as long as necessary based on our obligations and

business needs. This will be in line with our data retention policy. For more information, please

see the How long do you hold my information for? section of this Policy. Additionally, you can

request for your data to be deleted, subject to our legal and contractual obligations.

We will retain a record of your erasure request but we will not use this information for any other

purpose.

To ask for a copy of the information Wiremoney holds about you

You have the right to request details of the information we hold about you, a description of that

data, the purposes for which it is being used and any parties with which we share your information.

Where we are legally permitted to, we may decline your request or part of your request, but we will

provide an explanation with the response.

To ask Wiremoney not to further process your information

If you make a request for us to stop processing information, we will investigate to see if there is

compelling reason for processing to cease.

If you make a request for us to stop processing information, we will investigate to see if there is

compelling reason for processing to continue and will discuss the conclusion of the investigation

with you.

You can not object to the processing which is a legal obligation or where we must process your

information to satisfy a contract to which you are a party.

Also, you can object to marketing communications at any time. Please see the marketing section

for more details.

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To ask not to be subject to automated decision making and profiling

Wiremoney puts people first. There will not be any scenarios in which profiling or automated

decision making will have a legal impact on you without a person reviewing or making a decision

on the result. If you feel you may have been unfairly impacted, please contact us to discuss this

further.

Security

We store all data electronically and physically in a secure manner to protect its confidentiality,

integrity and availability. Data is stored on servers which are protected by actively maintained

firewalls. We make use of up-to-date anti-virus software and our servers have restricted access.

If you provide paper-based documentation for the purpose of identity verification these will be

stored electronically and the original will be destroyed securely or returned to you.

Transmission of data on the internet can never be completely secure. We do not and cannot

guarantee the security of information collected or transmitted electronically however, we take

reasonable care to safeguard your personal information.

Consent

By accessing our Services, you accept our Privacy Policy and Terms and Conditions (TC), Privacy

Policies and Terms of Service of our service providers listed above, and you consent to our

collection, storage, use and disclosure of your personal information as described in this Privacy

Policy. In addition, by using our Services you are accepting the policies and practices described in

this Privacy Policy. Each time you visit our website or use the Service, and any time you voluntarily

provide us with information, you agree that you are consenting to our collection, use, storage and

disclosure of the information that you provide, and you are consenting to receive emails or

otherwise be contacted, as described in this Privacy Policy. Whether or not you register or create

an account with us, this Privacy Policy applies to all users of the website and the Services.

What information we Process

Wiremoney collects both personal information about you and will Process this data for the

duration of the Services, as described in this Privacy Policy and our Terms and Conditions.

Personal Data includes customers’ information: identification and contact data (name, contact

details, username); billing information (such as payment card details, account details, payment

information); organization information (such as name, address, geographic location).

1. Definitions

1.1. "Customer" means a person or entity that is registered with Wiremoney to use the Services.

1.2. "Personal Data" means any information relating to an identified or identifiable natural or

legal person.

1.3. "Processing" means any operation or set of operations which is performed upon Personal

Data, whether or not by automatic means, such as collection, recording, organization,

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storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,

dissemination or otherwise making available, alignment or combination, blocking, erasure

or destruction. "Process", "Processes" and "Processed" shall be interpreted accordingly.

Transferring to third-party companies

We will never sell, rent, or lease your Personal Data to a third party, but we may share collected

information for the purposes described in this Privacy Policy with third-parties and service

providers that help Wiremoney provide, improve, promote or support our Services, that help with

our business operations and assist in the delivery of our Services, or who performing services for

us, in order to prevent damage to our property or for safety reasons, for example, payment

processors, hosting services, analytics, content delivery services, advertising partners, etc., in a

manner that is consistent with this Privacy Policy. We may also share information with third parties

if required to do so by law or if you violate our Terms and Conditions.

Age of consent

By using the Service, you represent that you are at least 18 years of age.

Merger or acquisition

In the event we undergo a business transaction such as a merger, acquisition by another company,

or sale of all or a portion of our assets, your Personal Data may be among the assets transferred.

You acknowledge and consent that such transfers may occur and are permitted by this Privacy

Policy, and that any acquirer of our assets may continue to Process your Personal Data as set forth

in this Privacy Policy.

Changes to our privacy policy

We may amend this policy from time to time. If we make any changes that will affect you, we will

be sure to let you know. This will always be published publicly on our website here.