Last Updated: June 11th, 2019

Introduction

Wirekeep values the trust our users and customers place in us when they give us access to their personal data. The Privacy Policy describes how we work to maintain that trust and protect that information. In particular, this Privacy Policy details our collection, use and disclosure of personal and non-personal data you give to Wirekeep when you access or use Wirekeep’s online and/or mobile services and websites, and software provided by Wirekeep on or in connection with such services or websites (collectively, the “Site”).

Personal Data and Non-Personal Data

Personal data (“Personal Data”) refers to any information that relates to an identified or identifiable individual, and non-personal data (“Non-Personal Data”) refers to any information that does not identify you as a specific individual. Please note that at all times Wirekeep will adhere to the applicable statutory definition in determining what is and is not Personal Data for the purposes of this Privacy Policy. Where this Privacy Policy refers to “information” or “your information” this may include both Personal and Non-Personal Data.

The Scope of Wirekeep’s Privacy Policy

This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy.

Occasionally, we may refer to this Privacy Policy in notices on the Site, including special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site. This Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice (e.g., with respect to the types of data collected or our uses or disclosures of such information). Wirekeep may amend this Privacy Policy at any time.

Changes to the Privacy Policy

Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Wirekeep is going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then Wirekeep will notify users via email and/or by posting a notice on Wirekeep’s Site for 30 days prior to such use or by other means as required by law.

Information Collected

From your account: You provide different types of information in order for Wirekeep to provide our services, products and features to you. Wirekeep associates this information with your Wirekeep user profile.

Through your activity: As part of the standard operation of the Site, Wirekeep may collect and analyze information from your computer or mobile device and actions taken on the Site, including, but not limited to, your transactional data, wire transfer information you searched for, your activity time on the Site and each page, page views, clicks, taps, session activity, browser type, operating system, type of device, MAC address, IP address and the domain name from which you accessed the Site.

This information will be used for internal purposes only, subject to any request by law enforcement or a court order. In connection with chargeable services, we will also collect payment information (e.g., the last four digits of credit card numbers and related verification information). Please note that Wirekeep only has access to the last four digits of credit card numbers, and does not store full credit card numbers.

Storage of Your Information

Wirekeep shall retain users’ Personal Data to the extent such retention is adequate, relevant and limited to what is necessary for the purposes for which they are processed. In particular, Wirekeep shall not retain Personal Data for any longer than necessary for the purposes of performing the processing outlined in this Privacy Policy.

Wirekeep may also store the information detailed in this section 2 ("Information Collected") of the Privacy Policy on its equipment or the equipment of third parties that Wirekeep has a relationship with. Such storage services will be governed by appropriate protections, as required by applicable rules.

The Legal Basis on Which Wirekeep Collects Your Personal Data

Wirekeep collects and processes your Personal Data on the basis of different legal grounds, depending on the nature of the Personal Data being provided and the type of processing involved. More information is provided on this here.

Performance of a Contract: Some of the Personal Data processed by Wirekeep is performed on the basis that it is necessary for the performance of our agreement with you.

Legitimate Interest: A second ground relied upon by Wirekeep for other types of processing of your Personal Data is that it is necessary for the purposes of legitimate interests pursued by Wirekeep.

Compliance with a Legal Obligation: A third ground relied upon for certain types of processing is that it is necessary in order to allow Wirekeep to comply with a legal obligation. An example of this would be where Wirekeep is required to retain business records for fixed periods of time in order to comply with local legal requirements.

Purposes, Uses and Disclosures of Information

We may use any information collected pursuant to this Privacy Policy, including Personal Data, for the purposes set forth in this Privacy Policy, to the extent applicable. We use your Personal Data to:

1. provide our services, products and features to you
2. to measure and improve those services
3. to protect our users and provide them with customer support.

Preventing Fraud and Spam

Wirekeep may also use information collected pursuant to this Privacy Policy to help diagnose problems with the Site and Wirekeep’s service, to prevent potentially fraudulent or illegal activities, and to protect individuals from other activities that may be detrimental to you or others. Wirekeep may investigate and disclose information from or about you or your use of Wirekeep if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet national security requirements.

We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.

Additional Uses and Disclosures of Non-Personal Data

In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclose, for any purpose, any Non-Personal Data, except where we are required to do otherwise under applicable law. If we combine any Non-Personal Data with Personal Data, then we will only use and disclose such combined information for the purposes described in this Privacy Policy while it is so combined.

Security

Wirekeep seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Data under Wirekeep’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other users, are not encrypted. Therefore, while we strive to protect your information, we cannot guarantee its security.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Data, by these companies.

Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our Cookie Policy for further information regarding Wirekeep’s use of Cookies.

Acquisitions and Other Reorganizations

Information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any change of ownership or control in Wirekeep’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy. Equally, information collected pursuant to this Privacy Policy, including Personal Data, may be disclosed to one or more third parties in connection with any acquisition or merger carried out by Wirekeep of such third parties.