Table of contents
- Our privacy commitment
- Conversation content
- Logs files
- Profile Information that you provide
- Data relevant to payment
- Processing of data in response to requests
- Additional technical data
- Address book data
- Usage data
- Support cases
- Third parties / data transfer to third countries
- Your legal rights as a data subject
- Notification of changes
1. Our Privacy Commitment
Our contact details are:
Wire Swiss GmbH
You can contact our Data Protection Officer (DPO) at email@example.com. You can address inquiries to them regarding your data, its protection and its treatment by Wire.
2. Conversation content
All conversation content is encrypted with strong encryption on the sender’s device and is only decrypted on the recipient’s device (also known as end-to-end encryption). This includes the files, images, audio, video, and location you decide to share in conversations or calls, which may also be personal and sensitive user data. Wire doesn’t hold the decryption keys, and our software contains no backdoor. Your conversations are yours — Wire‘s server has no decrypted access to them. Your end-to-end encrypted conversation content is temporarily stored in our server.
You may delete the content of the conversations on your device specifically and generally at any time.
In addition, Wire also uses transport encryption to encrypt metadata.
Wire only temporarily stores encrypted messages on its servers and automatically deletes them after they are sent to the recipient. This is done to enable Wire to send messages to users who are not currently online as soon as they are back online.
The legal basis for the transmission and storage of conversations is Art. 6 Para. 1 lit. b) GDPR (fulfillment of contract).
3. Logs files
When you use Wire services, we may collect technical data, so-called “log files”, with each access. The collection of log files serves the purpose of providing Wire services. The legal basis for the collection is Art. 6 § 1 b) DS-GVO (fulfilment of contract).
Log files are kept for a maximum of 72 hours, and only to facilitate troubleshooting, improve the service and prevent misuse. The legal basis for storage is Art. 6 § 1 f) GDPR (legitimate interest). Our legitimate interest is the trouble-free provision of the Wire services.
4. Profile Information that you provide
When you create an account with Wire, we ask you to provide a name and a mobile phone number or email address, and if you want, you can also upload a profile picture, which may also be personal and sensitive user data (“Profile Information”). The Profile Information you provide will be used for the purpose of providing Wire services and may be displayed to other Wire users when they search for you or connect to you through Wire services. If you have registered with a phone number, this information will not be displayed to other Wire users. If you registered with an email address, your email address may be visible to other users when using Wire Pro, depending on your preferences. We store your profile information only for the duration of your account usage in our servers. If you delete your account, we will delete your profile information immediately. You can change or delete your profile data at any time. The legal basis for the processing of your profile data is Art. 6 § 1 b) GDPR (fulfillment of contract).
5. Data relevant to payment
If you create a Team Admin account or Team Member account with Wire, we may ask you for additional information for billing purposes and may share that information with a billing provider (“Data relevant to payment”). In order to make purchases through Wire services using a Team Admin account, Team Admins must provide a payment method and may be required to provide additional information such as billing address, phone number, email address, and zip code if required for tax purposes or to complete billing. In addition, other types of information related to the specific transaction may be collected, such as transaction amount and duration. The legal basis for the processing of the above-mentioned data is Art. 6 § 1 b) GDPR (fulfilment of contract), if we collect and store data for tax reasons, the legal basis is Art. 6 § 1 c) GDPR (fulfilment of a legal obligation). We delete this data within 6 months after our contract with you is terminated or after the expiry of any existing legal obligation to retain data.
6. Processing of data in response to requests
If you send us an inquiry about our products as an interested party, we collect the information you provide, such as your name, e-mail address or other contact information you provide us with. We process this information for the purpose of answering your inquiry. The legal basis for the processing of your above-mentioned personal data is Art. 6 § 1 b) GDPR (contract initiation). We delete your data after the processing of your inquiry is completed.
If you have provided an e-mail address, Wire may send you e-mails to inform you of important changes (e.g. to confirm your e-mail address or to inform you that a new device has been added to your account). This is to help us provide you with a more secure experience with your account. The legal basis for the processing of this personal data is Art. 6 § 1 b) GDPR (fulfilment of contract).
If you have given us your consent for the purpose of receiving our newsletter with information about Wire’s offers and products by e-mail, Wire will process your e-mail address and name to send you the newsletter. The legal basis for the processing of your data is your consent in accordance with Art. 6 § 1 a) GDPR. You can unsubscribe from the newsletter at any time. For this purpose there is a link in every newsletter. We only store your data for this purpose for as long as the newsletter subscription is active.
8. Additional technical data
Wire stores additional technical data (such as the type of device through which you authorized the Wire application) to be able to route data between user devices. The Wire service is designed to keep additional technical data to the minimum required to operate the service.
9. Address book data
You are free to give Wire services access to your address book contacts. This is for the purpose of communicating with other users of Wire services. In this case, only hashed phone numbers are processed volatilely. The rest of your address book content is never uploaded to our servers.
10. Usage data
We process individual data about the use of Wire services in order to create anonymous usage statistics and crash logs. Insofar as personal data are processed for this purpose and your consent is required for processing, we will only process your data after you have given your consent (Art. 6 § 1 a) GDPR). Insofar as personal data is processed for this purpose and your consent is not required for processing, we process your data on the basis of legitimate interest (Art. 6 § 1 f) GDPR). Our legitimate interest is the trouble-free provision of the Wire services. You can prevent the processing of your data for these purposes at any time (see FAQ).
11. Support cases
When you contact Wire Customer Service for a support request, we process the personal information you provide in the support request for the purpose of processing your support request. The legal basis for the processing of your data for the processing of the support request is Art. 6 § 1 f) GDPR (legitimate interest). Our legitimate interest is to provide a support service for our customers. We delete your personal data processed for the processing of the support request after the processing of your request has been completed.
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Type and scope of processing
During your visit, the following personal data may be collected, for example:
- IP address,
- geographical location,
- type of browser,
- duration of the visit,
- pages viewed.
The collected information as well as the content of our website is stored on servers of our software partner HubSpot Ireland. We use HubSpot to analyze the use of our website. This allows us to constantly optimize our website and make it more user-friendly. We also use information to determine which of our company's services are of interest to customers and newsletter subscribers and to contact them for advertising purposes. In addition, we use the analysis to optimize our web offering for you.
In addition, we use the evaluation to optimize our website for you.
Purpose and legal basis
Type and scope of processing
We use Google Analytics from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as an analysis service for the statistical evaluation of our online offer. This includes, for example, the number of times our online offer is called up, sub-pages visited and the length of time visitors stay.
This information is used, among other things, to compile reports on website activity.
Purpose and legal basis
We process data using Google Analytics for the purpose of optimizing our website and for marketing purposes on the basis of your consent pursuant to Art. 6 (1) lit. a. GDPR.
13. Third parties / data transfer to third countries
To provide Wire services, Wire uses the services of the following third-party providers:
|Function of the third party
|Amazon Web Services EMEA SARL
|38 avenue John F. Kennedy, L-1855 Luxembourg
|Zeta Project Germany GmbH
|Development of the Wire services
|Rosenthaler Str. 40, 10178 Berlin, Germany
Wire undertakes to select only third-party providers for the provision of Wire services in the EU and/or Switzerland.
For the processing of personal data of business prospects and users of business accounts, Wire makes use of services of the following third-party providers:
|Function of the third party
|Website Hosting & Marketing Activities
Wire will not disclose your data to public authorities unless Wire is obliged to do so under Swiss law.
To the extent that Wire transfers personal data to third parties located outside the European Economic Area (EEA) (see also the overview of third party providers above), Wire will ensure that (i) the third party is located in a state that has been recognized by the EU Commission as having an equivalent level of data protection or or/and (ii) Wire has concluded “standard data protection clauses” with the third party within the meaning of Art. 46 § 2 c) GDPR or/and (iii) there is another guarantee within the meaning of Art. 46 or exception under Art. 49 GDPR. If you use third-party services such as YouTube, Spotify, Giphy etc. via the Wire application, all data that you share with these services is subject to their privacy policies.
14. Your legal rights as a data subject
As a data subject within the meaning of the GDPR, you have the following rights in relation to Wire:
You have the right to obtain information about the personal data that we store about you (Art. 15 GDPR), the right to correction (Art. 16 GDPR), deletion (Art. 17 GDPR) and restriction of the processing of your personal data (Art. 18 GDPR). You are also entitled to exercise your right to data transferability (Art. 20 GDPR).
You also have the right to object to the processing of personal data concerning you which is carried out in accordance with Art. 6 § 1 e) or f) GDPR. Unless we are still legally obliged or entitled to process your personal data, we will no longer process your personal data (Art. 21 § 1 GDPR). If you object to the use of your data for the purposes of direct marketing, we will no longer process the personal data concerned for these purposes (Art. 21 § 2 GDPR).
You may revoke any declarations of consent you have given at any time (Art. 7 § 3 GDPR). Revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation. You have the right to complain to a supervisory authority.
No automated decision making, including profiling, pursuant to Article 22 § 1 and § 4 GDPR by Wire takes place.
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