In this Policy, we use the terms "we", "us", and "our" (and other similar terms) to refer to Wirecard, and "you" and "your" (and other similar terms) to refer to merchants which are our customers, prospective customers, contacts or visitors to or users of any website of ours ("our site").
This Policy is an important document. We recommend that you read it carefully and print and keep a copy for your future reference. When you deal with Wirecard we will assume you agree to the terms of this Policy and consent to the collection, use, disclosure and processing of Personal Data in accordance this Policy, unless you tell us otherwise in writing.
How to contact us
If you have any questions about how we collect, use, disclose and process Personal Data, then please contact us using the details provided below:
Write to us at: Wirecard Singapore Pte Ltd, 8 Marina View, #40-01 Asia Square Tower 1, Singapore 018960.; or
E-mail us at: firstname.lastname@example.org
The Personal Data that we may collect from you
From initial contact through to providing you with our services or working together in other ways, we may collect Personal Data about you or from you. In particular, we may collect and process the following data:
- Personal data that you provide by filling in forms on our site. This includes information provided at the time of registering to use our site, applying for or subscribing to any of our services, posting material or requesting further services. We may also ask you for personal data when you report a problem with our site or our services.
- Records of payment transactions we process for you.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through our site or via use of our services and of the fulfilment of your transaction requests.
- Details of your visits to our site including and the resources that you access.
Your provision of personal data is voluntary. However, if you choose not to provide us with the Personal Data we ask for, it may not be possible for us to work with you or provide you with the products, services or information you require.
You must not provide us with the Personal Data about someone else (such as alternative named contacts) without first making sure that they are aware of the purposes for which we require the Personal Data and they have consented or are deemed to consent to the disclosure of the Person Data to us for such purposes. If you provide such third party Personal Data we will assume they have so consented, although we reserve the right to still ask for confirmation.
You should ensure that all Personal Data you provide to us is true, accurate and complete and promptly inform us of any changes or corrections required.
Contact details: We may collect, store and use your personal and/or professional contact details for the purpose of contacting and corresponding with you, as well as contact details for any organisation that you represent.
Know-your-client details: If you are an organisation, we may require you the Personal Data of your employees, directors, shareholders, partners, agents or representatives for the purposes of processing your application for our services and, upon approval of the application, the provision of the services you have signed up for. The Personal Data may include their passport or identity card number, citizenship and residency information, address, birth date, signature specimen and other personal particulars, credit history and financial information.
Confidential details, bank details: We may also hold confidential details about any matter on which you choose to engage us, as well as your bank account and/or other payment details for the purpose of paying our charges or processing your payment transactions at your request. In addition, we may also hold the information described in the "If you are a contact of Wirecard" bullet below.
Details we learn about you: We will obtain Personal Data from you and your communications with us via email, the internet, telephone exchanges and other interactions or via third parties, including employers, fraud prevention and credit reference agencies or other organisations involved in the support or provision of our services to you. We will also obtain Personal Data as a result of what we learn from the way you use our services and manage your user account with us, from the transactions we support and from the payments you make.
We may collect, store and use your contact details, copies of any e-mail, postal or other correspondence between you and us, and recordings of any voicemails that you choose to leave. We may also hold details of any contact preferences that you specify, such as requests to subscribe to publications that we may circulate from time to time, to receive news about any events we are organising or participating in, or to receive information about Wirecard and the services we provide.
Details of your use of our site: We may also collect, store and use certain, limited information relating to your use of our site for the purposes of better understanding the types of visitors who browse our site and improving our site offering. Other than information you choose to submit voluntarily to receive communications from Wirecard (as described in the "If you are a contact of Wirecard" bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in our Cookies Policy below.
However, if you login to any of our sites which are password protected, your usage of those websites may be monitored and we may collect, store and use any information relating to your use of those websites.
On occasion we may collect additional Personal Data for a specific purpose. In such circumstances we may provide specific additional notice about that processing and purpose at the time such Personal Data is collected and any disclosures made and information given at the point of such collection will also form a part of this Policy.
How we use your Personal Data
The ways in which Wirecard may use Personal Data obtained from or about you necessarily depends on the relationship you have with us. Examples of the ways in which we use the Personal Data that we collect include:
For contact and communication purposes: We may use your contact information and preferences to send you publications that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about Wirecard and the services that we provide. We will only contact you in accordance with the contact preferences that you have specified (which may include e-mail) and will not send you marketing communications where you have told us you do not wish to receive these. You can specify your contact preferences when registering online to receive communications from us (for example, through our site) or by subsequently advising us of your contact preferences using the contact details provided above.
To provide our services: We may also use Personal Data obtained from or about you to process your application(s) for our services and to provide our services to you, for example, opening, administering and running customer accounts, verifying identity of your representatives, conducting due diligence checks and screenings as may be required under applicable laws, dealing with any customer enquiries and requests for customer support and processing your customers’ payments. In addition, if we suspect that we have been given false or inaccurate information, we may record our suspicion together with any other relevant information.
Please note that we will assume, unless you instruct us otherwise in writing, that we may use and disclose the Personal Data obtained from or about you in such manner as we believe is reasonably necessary to provide our services to them (including as described in this Policy and as otherwise agreed between us). Where we process payment transactions for you, we will collect, store and use cardholders’ Personal Data for the purpose of processing payment and keep a record of such payment transactions. Cardholders’ Personal Data may include the card holder name, card number and transaction details (such as merchant name and location, date and time of transaction, transaction amount and status).
To collect our charges or costs in connection with other legal enforcement: We will use Personal Data to agree payment arrangements with you, and to collect our fees and costs owing to us in connection with legal enforcement.
For website analytics purposes: We may collect, store and use certain, limited information relating to your use of our site for the purposes of better understanding the types of visitors who browse our site and improving our site offering. Other than information you choose to submit voluntarily to receive communications from Wirecard (as described in the "If you are a contact of Wirecard" bullet above), the information we collect about website visitors does not enable any visitor to be individually identified, is processed only in anonymised, aggregated form, and will only be used for website analytics purposes as described in our Cookies Policy below.
For monitoring for quality assurance and training purposes: Wirecard strives to ensure that the services it delivers to its customers are of the highest possible standard. With this aim in mind, it may sometimes be necessary for us to monitor telephone and e-mail communications between our employees and third parties for the purpose of quality assurance and training or as otherwise permitted by law. We will only ever conduct communications monitoring in compliance with applicable law, and will at all times continue to protect the privacy of your communications in accordance with this Policy.
For administrative purposes: We may collect, store and use Personal Data for financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes.
For compliance purposes: We may collect, store and use Personal Data for in order to comply with obligations imposed or requests made by credit reference or fraud prevention agencies and other organisations of which we are a member or subscriber.
Who else may have access to your Personal Data
Wirecard may need to share your Personal Data with third parties. Where you supply us with Personal Data, we will assume, unless you instruct us otherwise in writing, that we can disclose the Personal Data obtained from or about you in such manner as we believe is reasonably necessary to provide our services to you (including as described in this Policy and in our terms and conditions), or as is required or permitted under applicable law.
Specific circumstances where we may share Personal Data with third parties might include:
Credit-checking agencies: We may check all Personal Data given by you with credit reference or fraud prevention agencies and other organisations and we may perform a search of your credit file in order to verify your identity. These agencies and organisations may keep a record of your information and the searches made (even if ultimately any application is unsuccessful or does not proceed). We may also be required to share Personal Data with them for the compliance purpose stated above.
Events: We may need to pass on your Personal Data (e.g. name, company, occupation) to a third party in connection with management of an event you have signed up for or expressed an interest in, in which case the details will only be used by the third party for that specific purpose.
Business partners, service providers and other affiliated third parties: To enable us to provide our services to you, we may need to share the Personal Data you provide with our business partners, service companies and/or service providers, for example, our partners involved in processing the transactions and/or supplying services associated with the credit, debit, charge or prepaid cards or tokens used in such transactions. We may need to disclose to such partners the details of the card holder, card number and any loads, withdrawals or transactions that are made.
Personal Data may also be transferred confidentially to banks, payment processors, card networks and payment schemes, such as MasterCard and card bureaus so that we can provide credit, debit, charge or prepaid card and associated services to you.
We will seek your express consent before third parties contact you by email or mobile phone about any offers they believe will interest you.
Wirecard offices: We may share your Personal Data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, in Singapore or other countries (our “Wirecard offices”) in order to achieve any of the purposes set out in this Policy. Specifically, our services use and rely on the back-office processing and storage services of our German parent company Wirecard AG and its systems and servers based in Germany. In order to support our services and associated transactions your Personal Data is shared with Wirecard AG but processed in accordance with the terms and security measures outlined in this Policy.
Disclosures required or permitted by law or regulation: In certain circumstances, please note that we may be required or permitted to disclose Personal Data under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.
Publicity: In keeping with market practice, unless you advise us in writing to the contrary, you consent to the disclosure of our involvement as your service provider for the purposes of publicising our services. We may also provide a general description of the work we've done for you, or a more detailed description if this information is already in the public domain or you expressly consent to this.
Other: We may disclose Personal Data in the event that we sell or buy any business or assets, in which case we may disclose Personal Data to the prospective seller or buyer of such business or assets. We may also disclose Personal Data if Wirecard or substantially all of its assets is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
International transfers of Personal Data (including to outsourced service providers)
As described above, from time to time, Wirecard may need to transfer your Personal Data to business partners, service providers and other Wirecard offices that are located in territories outside Singapore.
For example, we may provide customers' accounts and services from centres such as the USA and India and we may process payments through other organisations such as banks, payment processors, card networks and payment schemes.
In applying for an account or services from Wirecard you explicitly consent to the transfer of Personal Data as described above.
Please note that the legal regimes of some territories outside Singapore do not always offer the same standard of data protection as in Singapore, although we will ensure that your Personal Data is only ever treated in accordance with this Policy and, if you are a customer, our terms and conditions.
How we look after your Personal Data
We have in place what we believe to be appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful use, and against accidental loss, damage or destruction. We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.
If you or others on your behalf give us any Personal Data about another person, you take full responsibility for complying with any relevant data protection laws which apply to the provision of that Personal Data to us, and our use of it as explained in this Policy.
Access to and correction of Personal Data
You may request a copy of the Personal Data that we hold in relation to you. Upon receipt of your written request, with enough information to permit us to identify your Personal Data, we will disclose what we hold unless we are required or permitted by applicable law to decline your request.
Any access request may be subject to a fee to meet our costs in providing you with details of the Personal Data we hold about you.
We will also correct and amend any Personal Data that is inaccurate and, where required by the applicable law, notify any third party recipients of the necessary changes.
If you wish to access or correct your Personal Data please write to us at the address shown above.
For more information about cookies, we recommend that you visit http://www.allaboutcookies.org
Updates to this Policy
Please note that for legal, business or operational reasons we may from time to time update this Policy. We will highlight any material changes that we make to this Policy on our site. Each time we collect, use, disclose or process Personal Data, the latest version of this Policy in force at the time will apply.