What this Privacy Notice covers
W1TTY Global Ltd ("W1TTY", "we", "our" or "us") operates a platform accessible through the W1TTY application, which is available for download on your mobile device (the "W1TTY App"), and our website at www.w1tty.com (our "Website"), that allows users to view the balance of, and carry out and manage transactions conducted through their multicurrency electronic account (collectively, the "W1TTY Service").
This Privacy Policy, also called a Privacy Notice (the "Notice"), describes how we use information that identifies or is associated with you (your "personal information") when you interact with us via our Website or otherwise through the W1TTY Service. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a query or complaint.
This Notice may be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why we use it) we will highlight those changes at the top of the Notice and provide a prominent link to it for a reasonable length of time following the change (and, for any important changes to how we use your personal information, prior to the change taking effect).
Who is responsible for your personal information
Your personal information is collected by W1TTY Global Ltd, a company registered in England and Wales under company registration number 12810623.
If you would like to contact us, you can email us at support@w1tty.com.
W1TTY is committed to protecting your privacy. The effective management of all personal information, including its security and confidentiality, lies at the very heart of our business and underpins our practices and processes. We collect, use and are responsible for certain personal information about you. When we do so we are subject to applicable data protection laws and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
What information do we collect and how do we use it
We will collect, store and use your personal information for the purposes set out in more detail in this section.
Your information may be shared with some third parties as set out in more detail below.
Information users of the W1TTY Service (our "Users") and visitors to our Website provide to us
We collect most of our personal information directly from our Users and visitors to our Website, by telephone, post or email and/or via our Website or the W1TTY App.
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the W1TTY Service. In certain circumstances, if you do not provide personal information which is required, we will not be able to perform our obligations under the contract with you or may not be able to provide you with our products and/or services.
The following table sets out the categories of personal information that we collect directly from Users and visitors to our Website, how we use them and the legal basis we rely on for doing so:
Personal information we collect | How we use it | Legal basis we rely on |
Contact details such as your name, address, email and telephone number(s). | We use this information to set up your account on the W1TTY Service. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service).
If you access the W1TTY Service on behalf of a company, the processing is necessary for our and our customer's legitimate interests, namely providing access to and administering the W1TTY Service. |
We use this information to communicate with you about any queries you may have regarding your access to and use of the W1TTY Service. | The processing is necessary for our legitimate interests, namely administering the W1TTY Service and addressing user queries. | |
We use this information to send you service-related communications. | The processing is necessary for our legitimate interests, namely administering the W1TTY Service. | |
We use this information to send you marketing communications. | We will only process your personal information in this way to the extent you give us your consent to do so. | |
Details relating to communications between us, such as a note or recording of a telephone call, an email or letter sent, or other records of any contact with us. | If you contact us about your use of the W1TTY Service, we will use the content of those communications to respond to your queries and comments and to help us administer and improve the W1TTY Service. | The processing is necessary for our legitimate interests, namely administering the W1TTY Service, addressing user queries and comments, and to help us improve the W1TTY Service. |
Login information, such as the email and password that you use to set up your account. | We use this information to authenticate you and allow you to log in to your account on the W1TTY Service. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service).
If you access the W1TTY Service on behalf of a company, the processing is necessary for our and our customer's legitimate interests, namely providing access to and administering the W1TTY Service. |
Country of citizenship and country of residence. | We use this information to verify your eligibility to use the W1TTY Service. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service). |
We use this information to identify risks that may require further screening against UK and EU financial and other sanctions lists. | The processing is necessary to comply with a legal obligation to which we are subject. | |
Identification information such as information taken from identification documents like your passport or driving licence. | We use this information to verify your identity in connection with our anti-money laundering and "Know your Customer" obligations. | The processing is necessary in order to comply with a legal obligation to which we are subject. |
Biometric data, such as biometric templates generated from images of your face and your identity documents. | We use this information to verify your identity using automated identity verification software. In the event that we are unable to verify your identity using this process, the information submitted for identity verification will be subject to additional human review. | We will only process your personal information in this way to the extent you give us your consent to do so. |
Information about your precise location. | We use this information to confirm if you are in the country you say you are based in when you create a W1TTY account, in order to identify fraud risk. | We will only process your personal information in this way to the extent you give us your consent to do so. |
Information about beneficial owners and directors. If we enter into an agreement with a company to provide them with access to the W1TTY Service, we will collect information about that company's beneficial owners and directors, such as their names, the size of their shareholding, their identification documents and the results of any identity checks conducted on them. | We use this information to verify your identity in connection with our anti-money laundering and "Know your Customer" obligations. | The processing is necessary in order to comply with a legal obligation to which we are subject. |
Details about the transactions you make using your W1TTY account, including any payments you make or receive and any bank accounts you use to transfer to or withdraw money from your W1TTY account. | We use this information to process transactions you make on the W1TTY Service and provide you with an up to date balance of your W1TTY account on the W1TTY Service. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service). |
We use this information to identify and detect fraud. | The processing is necessary for our legitimate interests, namely the detection and prevention of fraud. | |
Employment information, such as your employer and your role at your employer. | If you are accessing the W1TTY Service on behalf of a company, we use this information to provide you with access to that company's account on the W1TTY Service. | The processing is necessary for our and our customer's legitimate interests, namely providing access to and administering the W1TTY Service. |
Information that we collect automatically
We also collect the following personal information about you and your use of the W1TTY Service automatically when you use the W1TTY Service:
Category of personal information | How we may use it | Legal basis for the processing |
Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.
| We may use information you provide to us about your location to monitor and detect fraud or suspicious activity in relation to your or a customer's account. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
Information about how you access and use the W1TTY Service.
For example, the IP address from which you access the W1TTY Service, how frequently you login and access the W1TTY Service, the time you access the W1TTY Service and how long you use it for. | We may use information about how you use and connect to the W1TTY Service to present the W1TTY Service to you on your device. | The processing is necessary for our legitimate interests, namely to provide the W1TTY Service to the user. |
Information about how you access and use the W1TTY Service.
For example, the IP address from which you access the W1TTY Service, how frequently you login and access the W1TTY Service, the time you access the W1TTY Service and how long you use it for. | We may use this information to monitor and detect fraud or suspicious activity in relation to your or a customer's account. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
We use this information to monitor the performance of, and improve the W1TTY Service and to develop new features of the W1TTY Service. | We will only use your personal information in this way to the extent you have given us your consent to do so. | |
We use this information to present the W1TTY Service to you on your device in accordance with your screen and window size and your browser settings. | The processing is necessary for our legitimate interests, namely providing you with access to the W1TTY Service. | |
Information about your device that you use to access the W1TTY Service, such as the type of device, operating system, browser, your Internet service provider or mobile network and your IP address. | We use this information to monitor the performance of, and improve the W1TTY Service and to develop new features of the Service. | We will only use your personal information in this way to the extent you have given us your consent to do so. |
Cookies and other trackers
The Website uses cookies and similar tracking technologies to collect information about your use of the Website and distinguish you from other users of the Website. Cookies are pieces of code that we transfer to your computer's hard disk to store or collect information.
We use these technologies to provide certain functionalities of the Website, such as the customer support chat functionality, as well as to collect information about how you access and use the Website.
For information about the cookies and similar trackers that we use on the Website, please refer to our Cookie Policy.
The W1TTY App also uses a mobile SDK for a similar purpose. Mobile SDKs are software packages that can be incorporated into mobile apps to deploy certain functionalities or collect information about how the application is used.
We use a mobile SDK provided by Mixpanel, Inc. to collect information about how users interact with the W1TTY App, such as the pages you view on the W1TTY App, how long you view them for, how frequently you log in to the W1TTY App and information about the device you use to do so. We use this information to monitor the performance of the W1TTY App, and to identify errors and improvements for the W1TTY App.
Other than cookies, Mobile SDKs and similar technologies that are required to operate the W1TTY Service, we will only use place cookies on your device or otherwise use these technologies to collect data from your device with your consent.
If you would like to withdraw your consent to non-essential cookies, you can do this by clicking on the floating cookie icon on the Website and updating your preferences. If you would like to withdraw your consent to the use of the Mixpanel mobile SDK, you can do so on the "About Us" page in your profile on the W1TTY App.
You also have the ability to opt out of all cookies by disabling cookies in your browser or mobile settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of the W1TTY Service. These settings will typically be found in the "options" or "preferences" menu of your browser. Please access the links below for information about how to do this on popular browsers and operating systems, otherwise you should use the "Help" option in your browser for more details:
(a) Cookie settings in Internet Explorer
(b) Cookie settings in Firefox
(d) Cookie settings in Safari web and iOS.
You can also opt out of data collection through Mobile SDKs using your device settings:
(a) for iPhone and iPad users: in your device's settings access the Privacy > Analytics & Improvements tab, and toggle "Share With App Developers".
(b) for Android users: on your device's settings access the Privacy tab, and toggle "Send diagnostic data".
How long do we keep your information?
We will keep your information for a period of five (5) years from the date you close your W1TTY account and withdraw the balance of your W1TTY account, unless we are required to retain it for longer to comply with applicable law or if we believe your personal information may be necessary to deal with a complaint, investigation, dispute or legal claim.
We will also routinely refresh our information to ensure we keep it up-to-date. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Recipients of personal information
We may disclose personal information to third parties as follows:
- to companies within the W1TTY Global Ltd. company group;
- to other users of the products and/or services where you have provided your approval or where you have posted information online which is publicly available;
- to our professional advisers, suppliers or service providers (such as auditors, consultants, lawyers, insurers, marketing agencies and website hosts);
- to third parties including for the purpose of providing the products and/or services;
- to third parties such as banks, tax authorities, courts, regulators and security or police authorities where required or requested by law, or where we consider it necessary (e.g. to help trace funds where you are a victim of suspected financial crime and you have agreed for us to do so, or where we suspect funds have entered your account because of a financial crime);
- in the event that any additional authorised users are added to your W1TTY account, we may share information about the use of the account by any authorised user with all other authorised users;
- if we are defending a legal claim, we may share your personal information with our legal advisors and other experts engaged in the conduct of the claim;
- if we transfer part or all of our organisation the information may be transferred to prospective purchasers under suitable terms as to confidentiality; and
- if we are reorganised or sold, information may be transferred to a buyer who can continue the work of our organisation.
We only allow third parties to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information.
Marketing consent
We will only send marketing communications to you if you actively opt-in to receive them, either via agreeing to push notifications in the W1TTY App, and/or by consenting to marketing through non-App based channels (during the application process or any time thereafter). Non-App based channels include email, telephone, post and direct messages online (e.g. through social media).
You can withdraw your consent to receive such marketing communications at any time by changing your W1TTY App settings for push notifications, and/or by clicking on the unsubscribe link at the bottom of each marketing communication sent through non-App based channels.
Where your information will be held
The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations, including countries outside of the UK or EEA. These international transfers of your personal information will be made pursuant to appropriate safeguards, including:
(a) ensuring that the personal data is transferred to countries recognized by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or
(b) implementing appropriate contractual safeguards, including Standard Contractual Clauses approved by the European Commission and the UK Information Commissioner's Office.
We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.
If you wish to enquire further about the safeguards we use, please contact us using the details set out at the beginning of this privacy policy.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed unlawfully.
Your Rights
You have the following rights in relation to your information, which you can exercise free of charge:
- Withdraw Consent: where we have collected your consent – for example, to send you marketing communications.
- Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.
- Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
- Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.
- Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Transfer: you may request the transfer of certain of your personal information to another party.
You also have a right to lodge a complaint with a supervisory authority (data protection regulator), in particular in the country in the EEA where you are habitually resident, where we are based or where an alleged infringement of data protection law has taken place.
Right to object
In addition to the rights above, you also have a right to object to us processing your information in certain circumstances. Where we are processing your personal information based on legitimate interests you may challenge this. However, we may be entitled to continue processing your information based on our compelling legitimate grounds or where this is relevant to legal claims. You also have the right to object where we are processing your data in order to send you any direct marketing.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the ICO on individuals’ rights under the General Data Protection Regulation.
If you want to exercise any of these rights, please contact us in writing, providing us with enough information to identify you (e.g. your full name, address and account number) and the specifics of the right you want to exercise.
Links to third party website
Our Website, our W1TTY App, our products and/or services and other communications may, from time to time, contain links to third party websites.
The personal data that you provide through these websites is not subject to this Notice. If you follow a link to any of these websites, please note that these websites have their own privacy policies / notices which will set out how your information is collected and processed when visiting those sites.
Children
Our Website and App are not aimed at children under the age of 18. If you are under 18 years old, you should not submit any personal information to us via our Website or our W1TTY App without checking with your parent or guardian.