This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by Wisly UK Limited (“Wisly”, “us”, “The Company”, “we”, “our”) in connection with their service.

Contacting Us

If you have general questions about your account or how to contact customer service for assistance, please visit our online support center at https://support.wisly.io. For questions specifically about this Privacy Statement, or our use of your personal information, cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at [email protected]

The data controller of your personal information is Wisly UK Limited. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Collection of Information

We receive and store information about you such as:

  • Information you provide to us: We collect information you provide to us which includes:
    • your name and email address, the transactions, wallets, and other cryptocurrency holdings which you input on our platform. We do not store your payment information, which is directly sent to Stripe, without transiting into our databases.
  • Information we collect automatically: We collect information about you and your use of our service, your interactions with us. This information includes:
    • your activity usage activity (log in, log out)
  • your interactions with our emails
  • details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings
  • Service Providers: We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide emailing, accounting, to personalize and optimize our service, to process credit card transactions or other payment methods. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
  • Giving others access to your account: If you share or otherwise allow others to have access to your account, they will be able to see the data you have entered on our platform.
  • Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we may use cookies in some instances to authenticate you.
  • Performance and functionality cookies: These cookies are not essential, but they help us to personalize and enhance your online experience with Wisly. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors’ use of the Wisly service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service.

Use of Information

We determine your geography to offer the correct pricing and currencies to you when you visit our website and sign up.

We use information to provide you with the best service and software we can, which includes sporadically send you transactional emails, payment due reminders, receipts, invoices or any other account related transactional emails.

We also communicate with you concerning our service so that we can send you news about Wisly, details about new features special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests.

Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity). For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact our Data Protection Officer/Privacy Office by email at [email protected]. Please visit our online support center at https://support.wisly.io for more information about these topics.

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

Your Choices

Email. If you no longer want to receive certain communications from us via email simply access the “Communications Settings” option in the “Account” section of our website and uncheck those items to unsubscribe. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your account transactions.

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you.

You can most easily do this by sending us an email to pri[email protected] to make requests, or if you have a question regarding our privacy practices. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Please also see the “Your Choices” section of this Privacy Statement for additional choices regarding your information.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; you have the right to complain to a data protection authority about our collection and use of your personal information. Our main establishment within the European Union is in the Netherlands. Please visit our online support center at https://support.wisly.io for more information about these topics.

We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

Children

You must be 18 years of age or older to subscribe to the Wisly service. In certain jurisdictions, the age of majority may be older than 18, in which case, you must satisfy that age in order to become a member. While individuals under the age of 18 may utilize the service, they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Wisly service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the Wisly service. To see when this Privacy Statement was last updated, please see the “Last Updated” section below.

Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons), as well as resettable device identifiers, for various reasons. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do, and your choices regarding their use.

Cookies and similar technologies, web beacons, and resettable device identifiers

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL) as well as native iOS and Android capabilities (Async Storage, Keychain, etc.). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies. You can modify your cookie preferences here.

Last Updated: 24 September, 2020