Privacy Policy

Effective on: May 25th 2017

This privacy policy (“Policy”) describes how DirektWire UK Ltd (“DirektWire”) collects and uses your personal information, including the information you provide on this website, www.direktwire.com, (“Website”) owned and operated by DirektWire(“we”, “us” or “our”) and/orour mobile application (“App”). It also describes the choices available to you regarding our use of your personal information in providing you with an online facility for transferring money to others (the “Services”) and how you can access and update this information. Please read this Policy carefully as it is legally binding when you use our Services.

For the purpose of the relevant data protection regulations, the company in charge of your information (also known as data controller) is DirektWire UK Ltd of Office 2085, 1 Fore Street Avenue, London EC2Y 9DT. If you have any questions about this Policy, please email us at privacy@direktwire.com

1. How do we protect your personal information

1.1 The security of your personal information is important to us. All information you provide to us is stored on our secure servers. When you enter certain information including payment transactions, we encrypt such information using reasonable security measures in line with generally acceptable industry standards.

1.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share this password with anyone else and not to use this password for other services or products. Your password is stored on DirektWire’s serversin an encrypted form. We may however disclose your first name and the first letter of your last name to other users, who are transacting with you via the Services.

1.3 As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information during transmission; any transmission is at your own risk and outside our control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

1.4 We restrict access of your personal information to those employees of DirektWire who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorised access.

1.5 We strive to collect no more personal information than is required. This helps reduce the total risk of harm should data loss or a breach in security occur.

2. Information we may collect from you

DirektWireprocesses and stores personal information collected from you via your use of the Services or where you have given your consent.We may request, collect and use personal information about you including:

2.1 Information you give us.

(a) You may give us information about you by filling in forms when registering or using our Services or via correspondence e.g. email. This includes information you provide when you register to use our Services, participate in discussion boards or other social media functions on our Website or App, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, personal description and photograph.

(b) We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under any applicable law.

(c) In providing the personal information of any individual (other than yourself) to us during your use of our Services, you acknowledge that you either have the appropriate authority to provide such personal information and have obtained prior consent from such individual to disclose his/her personal information to us, as well his/her consent to our collection, use and disclosure of such personal information, for the purposes set out in this Policy.If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please email us at privacy@direktwire.com.

2.2 Information we collect about you.

With regard to your use of our Services, we may automatically collect the following information:

(a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates.

(b) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

(c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

2.3 Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and credit reference agencies.

3. Cookies

3.1 Our Services use cookies to remember users’ settings, for authenticationpurposes and to build an ongoing picture of each user’s needs and preferences. This distinguishes you from other users as we are able to tailor the Services to meet your needs and enhance your experience of the Services.

3.2 You may control the use of cookies at the individual browser level by changing your browser settings. If you reject cookies, you may still use our Services but your ability to use some features or areas of our Website may be limited. Please see our Cookies Policy for further information and how to opt out.

4. How we use your personal information

By accepting the terms of this Policy, you acknowledge that we may use your personal information in the following manner:

4.1 To register and create an account for you with DirektWire;

4.2 To communicate with you and to provide, deliver, improve and personalize the Services to you;

4.3 To comply with any applicable legal and/or regulatory requirements;

4.4 To notify you about any changes to our Services;

4.5 To keep our Services safe and secure;

4.6 To administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

4.7 To improve our Services and to ensure that they are presented in the most effective manner;

4.8 To allow you to participate in interactive features of our Services, when you choose to do so; and

4.9 To measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you.

5. Choice/Opt-Out

5.1 We may provide you or permit selected third parties to provide you with newsletters or information via email about other similar products and services we feel may interest you.You may choose to stop receiving such information by following the unsubscribe instructions included in these emails or you can email us at privacy@direktwire.com.

5.2 We will also send you service related email announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. You do not have an option to opt out of these emails, which are not promotional in nature.

5.3 We may partner with a third party to either display advertising on our Website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on our Website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by sending us an email atprivacy@direktwire.com.You will continue to receive generic ads.

6. Disclosure of your personal information

6.1 We may share your personal information with selected third parties that provide services which help us enhance our business activities or customer service including:

(a) affiliates, business partners, suppliers and sub-contractors in connection with the provision of the Services;

(b) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and

(c) analytics and search engine providers that assist us in the improvement and optimisation of our Website.

6.2 We may disclose your personal information to third parties:

(a) in the event that we are involved in a merger, acquisition or sale of all or any portion of our business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;

(b) if you request a service or product that is administered by a third party, in order to allow us to respond to the request. If such third party is working for DirektWire, it may also send back to DirektWireany new information obtained from you;

(c) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions; or to protect the rights, property, or safety of DirektWire and its Services, our subscribers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;

(d) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;

(e) to prevent and detect fraud or crime. We reserve the right to report to law enforcement agencies any activities that we believe in good faith are unlawful including exchanging information with other companies, organisations and agencies for the purposes of fraud protection;

(f) in response to a subpoena, warrant, court order, or as otherwise required by law;

(g) to assess financial and insurance risks;

(h) to recover debt or in relation to your insolvency; and

(i) to develop customer relationships, services and systems.

7. Where we store your personal information

The personal information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom. It may also be processed by staff operating outside the UK who works for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

8. Links to other websites

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal information to these websites.

9. Social Media Widgets

Our Website includes Social Media Widgets or features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our Website to provide specific services from another company (e.g. displaying the news, opinions, music, etc.) Personal information, such as your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.

10. Testimonials

We display personal testimonials of satisfied customers on our Website in addition to other endorsements, where you have agreed with a third party review site that we may do so. If you wish to update or delete your testimonial, you can contact us at privacy@direktwire.com.

11. Access to information

11.1 Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. You may request to review, delete or update your personal information to ensure it is accurate, by contacting us at privacy@direktwire.com. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

11.2 We will retain your information for as long as your account is active or as needed to provide you the Services, including a record of your transactions on our Website or carried out on the App. If you wish to cancel your account or request that we no longer use your information to provide you with the Services, please contact us at privacy@direktwire.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and will securely delete your information when we no longer have a need to retain it.

12. Changes to our privacy policy

We may update this Policy to reflect changes to our information practices. Any changes we make to this Policy will be posted on this page and if we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website or via a link from your App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

13. Notification in the event of breach

It would be very unlikely, but if a breach in the security of personal information were to occur, we will notify you if you are actually or potentially affected. In this event we will contact you via the email address you provided or publication on DirektWire’s website. We reserve the right to delay notification if this is requested by law enforcement or other authorities, or if giving notice immediately will increase the risk of harm to end-users overall.

14. Contact

14.1 Questions, comments and requests regarding this Policy are welcome and should be addressed toprivacy@direktwire.com (indicating “PRIVACY REQUEST” in the message subject).

14.2 If you contact us by e-mail, we may keep a record of your correspondence and ask for your name and contact information in order to send you a reply.