1. WHO WE ARE

This data privacy, use and retention policy (the "Privacy Policy") applies to personal information collection and processing activities carried out by the Wirex group company responsible for providing services to you. For the launch and transitional phase of Wirex One for EEA users, this is expected to be Wirex Europe sp. z o.o., unless the applicable Terms identify a different Wirex group company for a specific service or functionality.

Different Wirex companies may control and process your data depending on where you are ordinarily resident, the services you use, and the Wirex entity providing those services to you at the relevant time. The Wirex company that provides you with access to the relevant Wirex service and your Wirex Profile, as identified in the applicable Wirex terms of service, is the Wirex company directly responsible for handling your personal data.

For users moving from the legacy Wirex App to Wirex One, the controller of your personal data may change as part of the phased Wirex One rollout. Any such change will be notified to you before or at the time it becomes effective.

Our privacy email address for all Wirex companies is privacy@wirexapp.com. We respect individuals' rights to privacy and to the protection of personal information. The purpose of this Privacy Policy is to explain how we collect and use personal information in connection with our business. "Personal information" means information about a living individual who can be identified from that information, either by itself or when combined with other information.

We may update our Privacy Policy from time to time. When we do, we will communicate any changes to you and publish the updated Privacy Policy on our website. We encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

To find out about our use of cookies, please read our Cookie Policy.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA

For EEA users, the Wirex entity responsible for your personal data at Wirex One launch and during the transitional phase is Wirex Europe sp. z o.o., unless the applicable Terms identify another Wirex group company or third-party provider as responsible for a specific service or functionality.

Different components of Wirex One may be provided by different Wirex group companies or by licensed third-party partners. Where a third-party partner provides a regulated service, that partner may act as an independent controller for the personal data it processes in connection with that service, as explained in its own terms and privacy notice.

In the future, responsibility for Wirex One services and related personal data may transfer to another Wirex group company. We will not present such future entity as the current controller until the transfer becomes effective.

Where such a change affects the Wirex entity responsible for providing services to you or acting as controller of your personal data, we will update this Privacy Policy and notify you in accordance with applicable law before or at the time the change becomes effective.

The Wirex entity that provided your legacy services may continue to retain certain historical records where required or permitted for AML, tax, accounting, audit, complaints, legal claims, regulatory reporting or dispute-resolution purposes.

3. THE INFORMATION WE PROCESS

We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this Privacy Policy. Personal information may include:

1. basic personal information, including name and address, date of birth and contact details;

2. financial information, including account and transactional information and history;

3. goods and services we provide to you;

4. visual images and personal appearance, such as copies of passports or real-time biometric facial scans;

5. online profile and social media information and activity, based on your interaction with us and our websites and applications, including your login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile app security authentication, mobile phone network information, searches, site visits and spending patterns;

6. anonymised personal data from your contact book if you choose to enable the Send Money to Contacts feature;

7. Wirex One upgrade-related information, including upgrade eligibility status, Wirex One Terms acceptance status, legacy Wirex App user ID, Wirex One user ID, account-linking information, migration audit logs, Terms acceptance records, Privacy Policy acknowledgement records, device/session data and upgrade or onboarding failure information;

8. wallet and blockchain-related information, including public wallet addresses, account abstraction wallet addresses, transaction hashes, blockchain network information, token amounts, timestamps, wallet status and off-chain records linking your Wirex One profile to wallet activity; and

9. technical and security information relating to your use of Wirex One, including authentication metadata, passkey metadata, device identifiers, security events, app telemetry and wallet-interaction metadata.

We may also process certain special categories of information for specific and limited purposes, such as detecting and preventing financial crime or to make our services accessible to customers. We will only process special categories of information where we have obtained your explicit consent or are otherwise lawfully permitted to do so and only for the particular purposes and activities set out at Schedule B for which the information is provided. This may include biometric information, relating to the physical, physiological or behavioural characteristics of a person, including fingerprint or facial recognition or similar technologies to help us prevent fraud and money laundering.

Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data with taxation, law enforcement and regulatory bodies.

We do not intend to write direct personal identifiers, such as your name, email address, phone number, residential address or KYC documents, to public blockchain records. Public blockchain records may nevertheless contain wallet addresses, transaction hashes, timestamps, token amounts and other transaction data that may be linked to you through off-chain records held by Wirex or third parties.

4. HOW WE OBTAIN INFORMATION

Your information is made up of all the financial and personal information we collect and hold about you, your business and the proprietors, officers and beneficial owners of that business and your transactions. It may include:

1. information you give to us;

2. information that we receive from third parties, including other Wirex group companies, third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other financial institutions where permitted by law;

3. information that we learn about you through our relationship with you and the way you operate your accounts or services, such as the payments made to and from your accounts;

4. information that we gather from the technology which you use to access our services, for example location data from your mobile phone, an IP address or telephone number, and how you use it, for example pattern recognition. This includes information from the contact book stored on your device if you enable the Send Money to Contacts feature;

5. first party and third party cookies when you access our services, for more details please read our Cookie Policy; and

6. information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

7. information generated during Wirex One account creation, wallet provisioning, authentication, migration, verification import, account linking, balance reconciliation, card reassignment, VIBAN or payment-account access, support and failure handling; and

8. information obtained from public blockchain networks, blockchain infrastructure providers, wallet infrastructure providers, transaction monitoring providers and other service providers supporting Wirex One.

5. YOUR RIGHTS

We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table at Schedule A. If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection team, please contact us at privacy@wirexapp.com.

Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the Wirex app or Wirex One.

If our relationship with you is terminated, for example if you choose to close your Wirex account, you may request the erasure of your personal data by contacting privacy@wirexapp.com. Please note that Wirex will only comply with such requests to the extent it is legally obligated to do so and, depending on your account activity until that date, certain personal data may be maintained in accordance with anti-money laundering and counter-terrorist financing legislation to which Wirex is subject.

Where your data is split between legacy Wirex App systems, Wirex One systems, third-party regulated service providers and public blockchain networks, we will assess your rights request against the data we control. Public blockchain records are not controlled by Wirex and may not be capable of deletion or alteration by Wirex.

If you acknowledge this Privacy Policy as part of the Wirex One onboarding or upgrade flow, that acknowledgement confirms that you have read the information provided. It is not treated as GDPR consent for core service processing.

6. CHANGES TO THE WAY WE USE YOUR INFORMATION

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change, we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the Wirex app or Wirex One.

Where the change relates to the Wirex One upgrade, a new service model, non-custodial/on-chain functionality, or a future change of controller within the Wirex group, we will provide appropriate notice and update this Privacy Policy before or at the time the change becomes effective, as required by applicable law.

7. HOW WE MAY USE AND SHARE YOUR INFORMATION WITH OTHER WIREX GROUP COMPANIES

We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other Wirex group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in a table in Schedule B, Purposes of Processing.

As part of the move from the legacy Wirex App to Wirex One, we may transfer, link, reassign or make available your eligible Wirex App information to another Wirex group company that provides or will provide Wirex One services to you. This may include your profile details, contact details, verification status, account identifiers, supported balances, card and payment account information, service records, transaction history, wallet addresses, support records and migration audit records and upgrade audit records.

The receiving Wirex group company will process your personal data as described in this Privacy Policy and in the applicable Wirex One Terms. The original Wirex entity may continue to retain certain historical records where required or permitted for AML, tax, accounting, audit, complaints, legal claims, regulatory reporting or dispute-resolution purposes.

8. SHARING WITH THIRD PARTIES

We will not share your information with anyone outside of the Wirex group except:

1. where we have your permission;

2. where required to provide your product(s) or service(s). This may include sharing your name with other Wirex customers if you are already in the contact book stored on their device or when we are required to do so by applicable law;

3. where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;

4. with other financial institutions and third parties where required by law to help recover funds that have entered your account as a result of a misdirected payment by such a third party;

5. with third parties providing services to us, such as market analysis and benchmarking, correspondent banking, and agents and sub-contractors acting on our behalf, such as the companies which print our packing labels and provide your currency accounts;

6. with other financial institutions 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 as a result of a financial crime;

7. with debt collection agencies;

8. with credit reference and fraud prevention agencies;

9. with third-party guarantors or other companies that provide you with benefits or services associated with your product or service;

10. where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;

11. in anonymised form as part of statistics or other aggregated data shared with third parties; or

12. where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

Where required to provide Wirex One services, we may share your information with third-party technology and infrastructure providers that support account creation, identity verification, wallet infrastructure, blockchain connectivity, transaction monitoring, fraud prevention, customer support, analytics and communications. These providers may include identity verification providers, wallet infrastructure providers, blockchain infrastructure providers, card and payment partners, VIBAN and payment-account providers, cloud providers, notification providers and support tools.

We may also process or receive wallet and transaction information from public blockchain networks and blockchain infrastructure providers. Public blockchain records are not controlled by Wirex and may remain publicly available even if your off-chain Wirex account data is deleted or restricted.

If you ask us to, we will share information with any third party that provides you with account information or payment services. If you ask a third-party provider to provide you with account information or payment services, you are allowing that third party to access information relating to your account. We are not responsible for any such third party's use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you. Wirex will not share your information with third parties for their own marketing purposes without your permission.

9. TRANSFERRING INFORMATION OVERSEAS

We may transfer your information to, or your information may be collected directly by, organisations in other countries, including other Wirex group companies, on the basis that anyone to whom we pass that information or who collects it directly protects it in the same way we would and in accordance with applicable laws.

As part of the Wirex One upgrade and any future controller transition, your information may be accessed by or transferred to Wirex group companies, service providers or infrastructure providers located outside your country of residence, including where this is necessary to provide Wirex One services, support Wirex One upgrade, maintain security, comply with legal obligations or manage group operations.

In the event that we transfer information to countries outside of the European Economic Area, which includes countries in the European Union as well as Iceland, Liechtenstein and Norway, we will only do so where:

1. the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;

2. the transfer has been authorised by the relevant data protection authority; and/or

3. we have entered into appropriate contractual safeguards with the organisation with which we are sharing your information, such as standard contractual clauses approved by the European Commission, the UK International Data Transfer Agreement or UK Addendum where relevant, or another lawful transfer mechanism required by applicable data protection law.

10. MARKETING INFORMATION

Marketing communications are separate from service communications about your account, Wirex One upgrade, legal terms, privacy updates, controller changes, service availability, security or compliance matters.

We may send you relevant marketing information, including details of other products or services provided by us or other Wirex group companies which we believe may be of interest to you, by postal or electronic communication methods, including email and SMS, where permitted by applicable law.

Where applicable law requires your consent for electronic marketing, we will rely on that consent. Where applicable law permits marketing under a soft opt-in or similar rule, we may rely on that rule, subject to your right to opt out at any time.

If you change your mind about how you would like us to contact you, or you no longer wish to receive marketing material from us, you can unsubscribe from our marketing emails by clicking "unsubscribe" in any emails we have sent, unsubscribe from our marketing text messages by texting "STOP" in any text messages we have sent, or contact us at privacy@wirexapp.com.

11. COMMUNICATIONS ABOUT YOUR ACCOUNT

We will contact you with information relevant to the operation and maintenance of your Wirex account, Wirex Profile or Wirex One services, including updated information about how we process your personal information, by a variety of means including email, text message and in-app notifications. If at any point in the future you change your contact details you should tell us promptly about those changes. We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule B, Purposes of Processing.

We may contact you with service-related communications about the Wirex One upgrade, changes to the Wirex entity responsible for your services or personal data, updated Terms, updated Privacy Policy, service availability, legacy Wirex App run-off, read-only access, account upgrade status and any action required from you. These communications are service communications and are separate from marketing communications.

12. FRAUD PREVENTION

We may access and use information from fraud prevention agencies when you open your account and periodically to:

1. manage and take decisions about your accounts;

2. prevent criminal activity, fraud and money laundering; and

3. check your identity and verify the accuracy of the information you provide to us.

Application decisions may be taken based solely on automated checks of information, for example from fraud prevention agencies and internal Wirex records. To help us make decisions on verifying your Wirex account, as well as transaction limits on your Wirex account, we look at information you give us when you apply for a Wirex account, including biometric data such as your photograph and/or facial scan, information regarding your location, age, nationality and/or citizenship and other information which enables us to verify your identity and perform a risk assessment for money laundering and fraud prevention purposes.

For Wirex One, fraud prevention and compliance checks may also include upgrade eligibility checks, device/session analysis, wallet-address screening, blockchain transaction monitoring, sanctions screening, Travel Rule related checks where applicable, and review of on-chain activity connected to wallet addresses associated with your Wirex One profile.

You have rights in relation to the automated decision-making used in the verification process, including a right to attempt account verification again, or contact our Customer Support team if your application is refused. We will also profile your Wirex account to assign a risk rating for the purposes of fraud and unusual transaction monitoring and unauthorised access prevention. The information we will use to profile you will include your age, bank country of residence and status as a politically exposed person or otherwise.

We will continue to collect and monitor information about how you manage your Wirex account including your account balance, payments into your account, the regularity of payments being made, and any default in making payments, while you have a relationship with us. This information may be made available to other organisations, including fraud prevention agencies and other financial institutions, so that they can take decisions about you. If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to relevant fraud prevention agencies. Law enforcement agencies and other organisations may access and use this information.

We cooperate fully to the extent of our legal obligations in the prevention of fraud, money laundering and counter-terrorism. If we, or a fraud prevention agency, determine that you pose a fraud, money laundering or other criminal risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you. A record of any fraud, money laundering or other criminal risk will be retained by fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

13. HOW LONG WE KEEP YOUR INFORMATION

By providing you with products or services, we create records containing your information, such as customer account records and activity and transaction records. Records can be held on a variety of media, physical or electronic, and formats, but they are primarily held electronically. We manage our records to help us better serve our customers and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.

Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant Wirex company is located and the applicable local legal or regulatory requirements. We and other Wirex group companies normally keep customer account records for up to six years after your relationship with Wirex ends. Retention periods may be changed from time to time, or waived where deemed low-risk, based on business or legal and regulatory requirements.

Where there has been no activity on your Wirex account since it was opened, we may delete your data after a period of 6 months, as you will be deemed an "unactivated user". If there has been any transactional activity on your account, we will maintain your data until you request that we delete it, unless we are obligated to maintain such data to comply with our legal obligations.

Where you move from the legacy Wirex App to Wirex One, some records may remain with the Wirex entity that originally provided your legacy services, while other records may be transferred, linked or made available to the Wirex group company responsible for Wirex One. Legacy records may be retained where required or permitted for AML, tax, accounting, audit, complaints, legal claims, regulatory reporting or dispute-resolution purposes.

Off-chain Wirex One records, including account records, profile information, wallet records, support records, upgrade logs and transaction-related records, will be retained in accordance with the applicable retention schedule.

Public blockchain records are not controlled by Wirex and may be permanent. This means that information recorded on a public blockchain, such as wallet addresses, transaction hashes, timestamps and transaction amounts, may not be capable of deletion or alteration by Wirex.

We may on exception retain your information for longer periods than those stated above, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that Wirex will be able to produce records as evidence, if they are needed. If you would like more information about how long we keep your information, please contact us at privacy@wirexapp.com.

SCHEDULE A - YOUR RIGHTS

1. Access - You have a right to get access to the personal information we hold about you.
If you would like a copy of the personal information we hold about you, please contact us at privacy@wirexapp.com. For EEA Wirex One users during the launch and transitional phase, your request will be routed to Wirex Europe sp. z o.o. as controller unless another controller is identified in the applicable Terms for the relevant service. You will be required to complete a form outlining your request and provide proof of your identity to ensure we are dealing with the account owner.

2. Rectification - You have a right to rectification of inaccurate personal information and to update incomplete personal information.
If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information. Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you. For more information, please email privacy@wirexapp.com.

3. Erasure - You have a right to request that we delete your personal information.
You may request that we delete your personal information if you believe that we no longer need to process your information for the purposes for which it was provided, we have requested your permission and you wish to withdraw your consent, or we are not using your information in a lawful manner. Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you. Public blockchain records are not controlled by Wirex and may not be capable of deletion or alteration by Wirex. Legacy records may also be retained where required or permitted by law.

4. Restriction - You have a right to request us to restrict the processing of your personal information.
You may request us to restrict processing your personal information if you believe that any of the information that we hold about you is inaccurate, we no longer need to process your information for the purposes for which it was provided but you require the information to establish, exercise or defend legal claims, or we are not using your information in a lawful manner. Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.

5. Portability - You have a right to data portability.
Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. This right applies to data controlled by Wirex and does not require Wirex to alter public blockchain records that are outside Wirex's control.

6. Objection - You have a right to object to the processing of your personal information.
You have a right to object to us processing your personal information for purposes based on legitimate interests, unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information.

7. Marketing - You have a right to object to direct marketing.
You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. For more information see Section 10.

8. Withdraw consent - You have a right to withdraw your consent.
Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities. Acknowledging this Privacy Policy is not treated as consent for core Wirex One service processing.

9. Lodge complaints - You have a right to lodge a complaint with the regulator.
If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you may also contact the relevant Data Protection Authority. For EEA customers, a list of supervisory authorities is available through the European Data Protection Board website.

SCHEDULE B - PURPOSES OF PROCESSING

We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other Wirex group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below:

1. Contractual necessity
We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. This may include processing to: assess and process applications for products or services; provide and administer those products and services throughout your relationship with Wirex; open, set up or close your accounts or products; execute your instructions; process transactions; make payments to third parties; resolve queries or discrepancies; manage and maintain our relationships with you; administer any credit facilities or debts; and communicate with you about your account(s) or the products and services you receive from us. For Wirex One, this also includes account creation, Wirex Profile setup, upgrade initiation, upgrade authentication, transfer, linking, reassignment or recreation of eligible user data, wallet provisioning, off-chain wallet records, VIBAN/payment-account access, card functionality, balance reconciliation, service notifications and support or failure handling.

2. Legal obligation
When you apply for a product or service and throughout your relationship with us, we are required by law to collect and process certain personal information about you. This may include processing to: confirm your identity, including using biometric information and facial recognition technology and other identification procedures; perform checks and monitor transactions and location data for the purpose of preventing and detecting crime and complying with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions; share data with police, law enforcement, tax authorities, government agencies or fraud prevention agencies where we have a legal obligation; deliver mandatory communications; investigate and resolve complaints; manage contentious regulatory matters, investigations and litigation; maintain effective risk processes; and monitor dealings to prevent market abuse. For Wirex One, this may also include verification import, sanctions screening, wallet-address screening, blockchain transaction monitoring, Travel Rule related checks where applicable, regulatory reporting, audit logs and retention of legacy records required for AML, tax, accounting, complaints, disputes and legal claims.

3. Legitimate interests of Wirex
We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. This may include processing to: monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services; ensure business continuity and disaster recovery; ensure network and information security; prevent cyber-attacks, unauthorised use of our systems and websites, and crime; protect your personal data; provide assurance on Wirex's material risks; perform accounting and reporting; protect our legal rights and interests; enable a sale, reorganisation, transfer or other transaction relating to our business; understand our customers' actions, behaviour, preferences, expectations, feedback and financial history to improve our products and services; assess customer service quality; analyse complaints; compensate customers where appropriate; and manage risk and financial crime prevention. For Wirex One, this may also include secure upgrade, identity matching, fraud prevention, device/session analysis, account linking, app telemetry, role-based access controls, support routing, product analytics, service resilience, wallet-address visibility controls, future intra-group controller transition, DSAR routing and retention split between legacy and Wirex One records.

4. Consent
Where we rely on your permission to process your personal information, including where explicit consent is required for certain special-category data processing, we will make this clear to you. You may withdraw your consent at any time.

5. Marketing
We may process your information for direct marketing where permitted by applicable law. You may object to direct marketing at any time. Service communications about Wirex One upgrade, controller changes, updated Terms, updated Privacy Policy, service availability, security, compliance or action required from you are not marketing communications.