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 you as the user of our services and products.
This policy is an important document. We recommend that you read it carefully. By registering for your Supercard via the Supercard App and by using your Supercard, you agree to the uses of your personal information as described in this policy.
The travel insurance benefits which you may be eligible to receive as a Supercard cardholder are provided by our partner, Inter Partner Assistance, Dublin a branch of Inter Partner Assistance, Belgium which is regulated by the National Bank of Belgium and is part of the AXA Group (“AXA”). For more details about these travel insurance benefits, please refer to the Supercard Terms and Conditions, and specifically, the Supercard Travel Insurance Benefits Schedule. That schedule includes information on how AXA will use your personal information. By making any claim or potential claim under the travel insurance, you agree to the uses of your personal information as described in that document.
How to contact us
If you have any questions about how we collect, store and use your personal information or would like a copy of the information we hold about you, then please contact us. You can:
- Write to us at: The Data Protection Officer, Wirecard Card Solutions Limited at Grainger Chambers, 3-5 Hood Street, Newcastle upon Tyne, NE1; or
- E-mail us at: firstname.lastname@example.org
If you request copies of the information we hold about you, we may charge you a statutory fee of £10 to help meet our costs in providing you with this information.
The personal information that we collect from you
We, or Travelex on our behalf, collect the following personal information about you through your Supercard and the Supercard App:
- Your name, residential address, email address, mobile phone number, date of birth, user identifier, password and any other information which you provide when you use the Supercard or register to use the Supercard via the Supercard App;
- Your VISA or MasterCard 3D Secure debit or credit card number, expiry date, security code and other details which you link to your Supercard to fund transactions or which you provide to us when you register to use the Supercard via the Supercard App;
- Your locationsuch as the country you are in when you use your Supercard;
- Details of any communications with you (via email, the internet, our call centre or via third parties including Travelex) when you contact us to report a problem or raise a query including details obtained through your communication with our customer services team and the Service Hotline;
- Details of transactions you carry out using your Supercard and of the fulfillment of your transaction requests;
- Information from fraud prevention and credit reference agencies or other organisations involved in the support or provision of the Supercard, Supercard App and associated services; and
- Information about how you use and manage your Supercard, your Supercard App and associated services, from the transactions we support and from the payments you make.
As part of the Supercard application process, we may also ask you to provide us with supporting documentation so that we can verify your identity, such as scanned copies or photos of identification documentation or a utility bill or bank statement.
How we use your personal information
We use your personal information to:
- provide your Supercard including sending your Supercard to you in the post;
- provide account services (such as registration and activation of the Supercard, activation and deletion of funding cards and access to your Supercard transaction history) to you via the Supercard App through our partner, Travelex;
- carry out electronic ‘know your customer’ (eKYC) checks, to check your identity and verify your address as required by law, and to assess your application. The eKYC check is not a credit check but it may leave a ‘soft’ footprint on your credit record. This will not affect your credit rating;
- verify your identity and to check that you are the cardholder when you use your Supercard;
- contact you about your Supercard and your Supercard App (including using your telephone number, mobile telephone number and email address to respond to or deal with any queries or issues you have raised);
- calculate and apply any Fees as described in the Terms and Conditions;
- monitor the restrictions/limits we set on the use of your Supercard;
- deal with any questions you may have about how we collect, store and use your personal information or with any request made by you for a copy of the information we hold about you;
- act as a point of contact for any travel insurance claims or potential claims you have which we will refer to AXA, as the provider of the travel insurance;
- to prevent or detect fraud, money laundering or any other criminal activity or to record any suspicious or fraudulent behavior or our suspicions about false or inaccurate information;
- comply with our legal obligations;
- collect our costs in connection with enforcement of our terms and conditions, if for example, it has been determined that you have been using your Supercard fraudulently. This includes contacting you to agree payment arrangements with you, and to collect our fees and costs owing to us in connection with such enforcement; and
- better understand how the Supercard and the Supercard App are being used by carrying out research and also carry out data analytics using anonymised data.
Who else may have access to your personal information
We may share your personal information with the following third parties in the following circumstances:
- Travelex to provide our services to you and to collect personal information from you during the registration and activation process for your Supercard via the Supercard App which is operated by Travelex and to report on how the Supercard is being used, including your transactional information.
- Credit reference agencies and databases or fraud prevention agencies and other organisations: to check all personal information given by you and to perform a search of your credit file in order to verify your identity. The agencies may keep a record of your information and the searches made (even if any application is unsuccessful or does not proceed). The searches will not be visible to lenders and will not affect your credit rating.
- Other Wirecard companies: to provide you with our services or to facilitate any intra-group reorganisations. Specifically, but without limitation, our services use and rely on the back-office processing and storage services of our German affiliate company Wirecard Technologies AG and its systems and servers based in Germany. Our services are managed by Wirecard UK and Ireland Limited.
- Card networks and payment schemes, such as VISA and MasterCard: to provide the Supercard and associated services to you.
- 3D Secure.
- AXA (for example, if they ask us to verify that you are a Supercard cardholder) so that AXA can administer the travel insurance services and can collect personal information from you when you make a claim or a potential claim under the travel insurance policy.
- Service providers, insurers and other affiliated third parties: to enable us to provide our services to you.
- Law enforcement, regulatory organisations, courts or other public authorities: to comply with law or regulation or in connection with proposed or actual legal proceedings or regulatory actions.
- Third party purchaser of our business: to continue providing the services to you if we sell any business or assets or if Wirecard or substantially all of its assets are acquired by a third party.
Monitoring for quality assurance and training
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 customers 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.
International transfers of personal information (including to outsourced service providers)
We may need to transfer your personal information to business partners, service providers and other Wirecard offices that are located in territories outside of the European Economic Area ("EEA"). For example, we may support the Supercard and associated services from centres such as the UAE and we may process payments through other organisations such as banks, payment processors, card networks and payment schemes which are located outside of the EEA. By using your Supercard and Supercard App, you explicitly consent to this. Please note that the legal regimes of some territories outside of the EEA do not always offer the same standard of data protection as those inside the EEA. We put in place strict confidentiality agreements (including data protection obligations) with our business partners and service providers to ensure your personal data is adequately protected.
How we look after your personal information
We have in place what we believe to be appropriate technical and organisational security measures to protect your personal information 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. We also have mutually agreed data processing obligations with our partner, Travelex.