Privacy

This privacy policy was last updated on 20180512

Finwire (“Finwire”, we“, ” us“ or ” our“) is committed to respecting your privacy. Please read this privacy policy carefully to understand our practices regarding your personal data and how we will treat it.

ABOUT OUR PRIVACY POLICY

This privacy policy applies to your access to and use of: the website finwire.com, news.finwire.com; articles.finwire.com the web-and future mobile application called ‘Newsweb’, (together the ”Platform“) including all content, services and products available at or through the Platform.

This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us.

By accessing and/or using the Platform, you are accepting and consenting to the practices described in this policy.

In this Policy we will explain:

What types of personal information Finwire collects and how it is used.

How we collect your personal information, including whether personal information is collected automatically.

How long Finwire retains your personal information. How and when Finwire shares your personal information with others. How we protect your personal information.

What choices and rights are available to you regarding the use of your personal information, including how to access and update personal information.

How personal information submitted to our Services or collected through our Services on behalf of or at the direction of our subscribers is treated.

How to update your communication preferences.

CONTACT INFORMATION

For the purpose of the General Data Protection Regulations (the “ GDPR”), the data controller is Finwire AB whose registered office is at Södra Larmgatan 6, 411 16 Gothenburg, Sweden.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@finwire.com

We may collect the following information:

1. Information you give us (Client Supplied Data): You may give us information about you by filling in forms on the Platform, for example when you register as a user of the Platform, register your billing details to become a customer, open a support request,take part in competitions, prize draws or surveys, or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, e-mail address, employment details, phone number and billing address.

2. Information we may automatically collect about you (Automatic Device Data): With regard to each of your visits to the Platform we may automatically collect the following information:

Visit information - including the full URL clickstream to, through and from the Platform (including date and time), page response times, errors, length of visits to certain pages, page interaction information, actions taken within the application and methods used to navigate away from the page;

Technical information - including the Internet Protocol address used to connect your device to the Internet, your login information, browser type and version, geographical location, browser plug-in types and versions and operating system.

3. Information provided by the web and future mobile application (Client Data): When using our services to connect to databases, including third party databases, we may pull data into the Platform which includes personal data. This is within your control, as we only pull data on your instruction.

The above types of information may not always contain personal data (i.e. data which identifies a person). Some of this information may instead contain non-personal data (i.e. data that does not identify you). As non-personal data is anonymous, this privacy policy does not restrict or limit our use and disclosure of non-personal data.

USE OF COOKIES

We are going to use cookies in order to provide a better service or identify which pages on the Platform are of special interest. A cookie is a small piece of information which a website stores on your web browser and which can later be retrieved.



HOW DO WE USE PERSONAL DATA?

We may process personal data in connection with the following purposes:

Client Supplied Data

to provide you with information and services that you request or subscribe to;

to bill and collect money owed to us by our Clients; to update our records and generally maintain your account with us; to provide you with special offers, promotions, surveys and other information about services we feel may interest you, where you consent to receiving such information; to notify you about changes to this privacy policy and other terms that you have agreed to; for research and development purposes to evaluate and enhance the Platform; and to deal with your queries, complaints or concerns,

Automatic Device Data

to provide our service to you; to present content from the Platform in an effective manner to you; to administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; as part of our efforts to keep the Platform safe and secure; to enforce compliance with applicable law.



DIRECT MARKETING - HOW TO UNSUBSCRIBE If you have consented to receive marketing communications from us via email you can change your mind and withdraw that consent. You can opt-out by clicking on the Unsubscribe link at the bottom of the email you’ve received or updating your user account settings. Alternatively, you can send an email to customer service at support@finwire.com



LEGAL BASIS The legal basis for which we act as Data Controller are as follows:

GDPR Article 6(1)(b) - processing of your personal data is necessary for the performance of our contract with you, our customer

GDPR Article 6(1)(c) - processing of your personal data is necessary for compliance with a legal obligation. Specifically, this relates to financial and accountability data

GDPR Article 6(1)(f) - processing of your personal data is necessary for legitimate interests of both Finwire and you as our customer. Specifically:

a. Ensuing Finwire’s systems are secure and for the purposes of performance and error monitoring and incident response

b. Improving the performance and user experience of the product

WHO PROCESSES YOUR INFORMATION?

We may disclose your personal data to the following persons:

1. Disclosure of information within Finwire: We limit access to your personal data to employees who reasonably need to process such information as described under this policy. In this situation we:

shall take commercially reasonable steps to ensure the reliability and appropriate training of any Authorized Employee.

shall ensure that all Authorized Employees are made aware of the confidential nature of Personal Data and have executed confidentiality agreements that prevent them from disclosing or otherwise Processing, both during and after their engagement with Processor, any Personal Data except in accordance with their obligations in connection with the Services.

shall take commercially reasonable steps to limit access to Personal Data to only Authorized Individuals.

2. Disclosure of information to particular third parties: We may disclose your personal data to the following third parties:

The members of our group (which means our subsidiaries, our parent company and its subsidiaries.

3. Disclosure of information in certain circumstances: We may also disclose your personal data:

in the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or asset;

if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

if we are under a duty to disclose or share your personal data in order to comply with any legal obligations, or in order to enforce or apply our terms for use of the Finwire Newsweb and future mobile application and other agreements; or to protect the rights, property or safety of Finwire AB, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

WHAT DO WE DO TO SAFEGUARD PERSONAL DATA?

We have implemented safeguards and procedures to protect your personal data against loss or theft as well as unauthorised access and undue disclosure. We also use our best efforts to ensure that third parties who work with us agree to protect your personal data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential.

LINKS TO OTHER WEBSITES

The Platform may contain links to third party websites. However, we are not and shall not be held responsible for the content of such websites, or their privacy policies. If you visit another website, we advise you to review their privacy policy and other general terms of use.

The GDPR gives you the right to access and request a correction of personal data held about you. Your right of access can be exercised in accordance with the GDPR. Some access requests may be subject to a reasonable fee to meet our costs in providing you with details of the personal data we hold about you.

You have the right to access and correct your personal information. If you want to review or correct your personal information, you can login to the application and visit your account profile page, typically designated as “My Account”, or contact us through the Newsweb or use our mailadress: support@finwire.com

RIGHT TO DELETE PERSONAL DATA

If we processes your personal information on behalf of or at the direction of one of our subscribers, you should first look to that subscriber for assistance regarding the deletion of your personal information.

You have the right to request deletion of personal information we hold about you and we have the obligation to erase your personal information, where:

the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,

you withdraw consent on which the processing is based and where there is no other legal ground for the processing,

you object to the processing and there are no overriding legitimate grounds for the processing,

the personal information has been unlawfully processed, or

the personal information has to be erased for compliance with a legal obligation in the European Union or a Member State law to which Finwire is subject.

If you want to request removal of your personal information from our Websites or Services you may send us an email at the support-address. You can also request closure of your account. We will respond to your request as soon as possible but at most 10 days.

In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.

RIGHT TO WITHDRAW CONSENT

Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can do this by:

send us an email at the support-address. following the unsubscribe instructions included in emails.

CHANGES TO OUR PRIVACY POLICY

Any changes to the privacy policy will be posted here.

If we want to make material changes to the way we use your personal data, we will ask for your consent before we do so.