Privacy Policy

1. Introduction

Wirex Digital Services S.r.l. ("Wirex", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our Services, including our website, mobile application, wallet services, and crypto-backed loan services.

By using our Services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use our Services.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide to us, including:

• Account Information: Name, email address, phone number, date of birth, and government-issued identification documents
• Financial Information: Bank account details, payment card information, and transaction history
• Identity Verification: Passport, driver's license, or other government-issued ID, proof of address, and selfie verification
• Loan Information: Collateral details, loan application information, and repayment history
• Communication Data: Correspondence with our support team, feedback, and survey responses

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Data: Pages visited, features used, time spent on our Services, and click patterns
• Location Data: IP address, geolocation data (with your consent), and time zone
• Technical Data: Browser type, language preferences, and access times
• Blockchain Data: Public wallet addresses, transaction hashes, and blockchain activity

2.3 Information from Third Parties

We may receive information about you from third-party sources, including identity verification services, credit bureaus, financial institutions, and blockchain analytics providers.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service Provision: To provide, maintain, and improve our Services, including wallet and loan services
• Identity Verification: To verify your identity and comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements
• Transaction Processing: To process transactions, manage your account, and handle loan applications and repayments
• Security: To detect, prevent, and investigate fraud, security breaches, and other illegal activities
• Compliance: To comply with legal obligations, regulatory requirements, and court orders
• Communication: To send you service-related notifications, updates, and marketing communications (with your consent)
• Customer Support: To respond to your inquiries, provide customer support, and resolve disputes
• Analytics: To analyze usage patterns, improve our Services, and develop new features
• Legal Protection: To protect our rights, property, and safety, and that of our users and third parties

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

• Contract Performance: To fulfill our contractual obligations to you
• Legal Obligation: To comply with legal and regulatory requirements
• Legitimate Interests: To operate our business, prevent fraud, and ensure security
• Consent: When you have provided explicit consent for specific processing activities

5. Information Sharing and Disclosure

We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Identity verification and KYC/AML service providers
• Payment processors and financial institutions
• Cloud storage and hosting providers
• Analytics and marketing service providers
• Customer support platforms

5.2 Legal Requirements

We may disclose your information if required by law, regulation, court order, or government request, including to:

• Regulatory authorities and financial intelligence units
• Law enforcement agencies
• Tax authorities
• Courts and tribunals

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5.4 With Your Consent

We may share your information with third parties when you have provided explicit consent for such sharing.

6. Data Security

We implement industry-standard security measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Multi-signature wallet security
• Secure authentication and access controls
• Regular security audits and penetration testing
• Employee training on data protection
• Incident response procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal and regulatory obligations (typically 5-7 years for financial records)
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

When we no longer need your information, we will securely delete or anonymize it, subject to legal retention requirements.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

8.1 Access and Portability

You have the right to access your personal information and receive a copy in a portable format.

8.2 Correction

You can request correction of inaccurate or incomplete information.

8.3 Deletion

You may request deletion of your personal information, subject to legal and regulatory retention requirements.

8.4 Objection and Restriction

You can object to certain processing activities or request restriction of processing.

8.5 Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time.

8.6 Marketing Opt-Out

You can opt out of marketing communications by clicking unsubscribe links or contacting us directly.

To exercise these rights, please contact us at privacy@wirexapp.com or through our Help Hub.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Authenticate your identity
• Analyze usage patterns and improve our Services
• Provide personalized content and advertisements
• Ensure security and prevent fraud

You can control cookies through your browser settings. However, disabling cookies may affect the functionality of our Services.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data from the EEA to other countries, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission, to ensure your data is protected.

11. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information promptly.

12. Third-Party Links

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date. Your continued use of our Services after such changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Wirex Digital Services S.r.l.
Data Protection Officer
Email: privacy@wirexapp.com
Website: Help Hub

If you are located in the EEA and believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection authority.