Privacy Policy

This Privacy Policy is effective from 22nd November 2023.

Version Number: 2.0

This Privacy Policy (“Policy”) explains how we collect, use, and process your personal data when you use our website https://wowbrand.com/ (“Website”), our web applications (“Web App”), our mobile apps (“App”) and email messages that we send to you (jointly called “Services”), our hardware. If anything, here applies to only one of our Services or to customers in a particular country, we’ll explicitly point this out to you.

By continuing your interactions with us, such as by submitting information to us or using our Services, you confirm that you understand and consent to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) as described in this Privacy Policy.

Please note personal information relating to U.S. users that we collect in connection with the solicitation and/or provision of our payment services is subject to our Consumer Privacy Notice. In the event of conflict or inconsistency between this Privacy Policy and our Consumer Privacy Notice, the Consumer Privacy Notice will apply to that information. Other information we collect from our U.S. users will be subject to the provisions of this Privacy Policy.

1. Data Controller

The Data Controllers for the collection, processing, and use of personal information are listed in the table below. If you have any questions about how we protect or use your data, please email us at support@wowbrand.com.

2. Data we collect about you

Personal data, or personal information, means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. We will collect and process personal data about you as follows:

2.1 Information you give us.

• You may give us information about yourself when you sign up to use our Services, e.g., when you provide us with personal details, including your name and email address. This also includes information you provide through your continued use of our Services, your participation in discussion boards or other social media functions on our Website or App, through entering a competition, promotion, or survey, and by reporting problems with our Services. The additional information you give us for security, identification, and verification purposes may include your address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security/insurance number, national identification number, personal description, photograph, passport and/or National ID. If you fail to provide any of this information, it might affect our ability to provide our Services to you.
• The content of your communications with us, which we collect via telephone call recordings, online chat, emails, direct messaging, and other means.
• In some cases, including when you send or receive high-value or high-volume transactions or where we need to comply with anti-money laundering regulations, we may also need more identification information from you, including a copy of your bank account statements.
• In providing the personal data of any individuals other than yourself, including connected persons, you confirm that you have obtained consent from such individuals to disclose their personal data to us or our other WOW Payments entitled to provide this information to us. You also confirm that you have brought this Policy to their attention if legally necessary and have received their consent to our collection, use, and disclosure of such personal data for the purposes set out in this Policy. The term ‘connected person’ means an individual connected to WOW Payments through the use of our Services and could be an account holder, payment beneficiary, recipient of a designated payment, guarantor, director, shareholder, partners or members of a partnership, trustee, authorized signatory of a designated account, a friend you have recommended, individuals in your contact list or any other person who has a relevant relationship with WOW Payments.
• Please ensure that your personal data is current, complete, and accurate by logging onto your account and updating it whenever necessary.

2.2 Information we collect about you. When you use our Services, we may collect the following information:

• details of the transactions you carry out when using our Services, including the geographic location from which the transaction originates;
• technical information, including the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform, and, if you’ve installed the App, installed applications on your mobile device that have remote access permissions;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Website or App (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (including scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support service;
• information about your marketing and communication preferences.

2.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties and may receive information about you from them. This may include:

• the bank whose account you link to your WOW Payments account for the purpose of satisfying regulatory verification and linked accounts to transfer funds may provide us with your name, address and financial information, including source of funds and bank statement information, and transactional data;
• business partners may provide us with your name and address, as well as financial information, including card payment information;
• advertising networks, analytics providers and search information providers may provide us with pseudonymized information about you, including confirmation of how you found our website;
• in some jurisdictions, we may check the information you have provided to us with governmental or private identity record databases or with credit reference agencies to confirm your identity and to combat fraud.

2.4 Sensitive data.

• As part of our identity verification process we collect, use and store biometric data, namely:
  • We extract face scan information from photos and videos to compare pictures of you on identity documents with each other and with a selfie that you provide to verify your identity and for anti-fraud checks, and to improve these processes. We may ask you to specifically consent to the collection, use and storage of your biometric data during the verification process, where privacy regulations require it in your jurisdiction. If you do not consent, we offer alternate methods to verify your identity which may take longer. We will not disclose or disseminate any biometric data to anyone other than our identity verification providers, or when required by applicable laws and regulations, or pursuant to a valid order from a court. We never sell, lease, trade or other WOW Payments benefit from your biometric data. We will retain biometric data for the period necessary to complete the identity verification process, and in any case, no longer than 1 year after collection, unless required by law or legal process to keep it longer.
  • We monitor the way you log in and interact with our website or app in order to validate your identity and support the detection of fraudulent and suspicious attempts to access your WOW Payments Account;
  • If you consent to link your bank account to your WOW Payments account for the purpose of satisfying regulatory verification, we may also process a limited amount of sensitive data when we carry out verification of your financial documents.
• Your jurisdiction may have rules that classify other information described in section 2 as sensitive. All sensitive information is subject to appropriate levels of protection.

2.5 Children’s data. Our products and services are directed at adults and are not intended for children. We therefore do not knowingly collect data from children. Any data collected from a child before their age is determined will be deleted.

3. How we protect your personal information

3.1 We take the safeguarding of your information very seriously. The transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to ensure it stays secure, including:

• Communications over the Internet between you and WOW Payments systems are encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in;
• We update and patch our servers in a timely manner;
• Our technical security team proactively monitors for abnormal and malicious activity in our servers and services;
• When the information you’ve given us is not in active use, it is encrypted at rest.

3.2 We restrict access to your personal information to those employees of WOW Payments who have a business reason for knowing such information and third-party service providers processing data on our behalf. All WOW Payments employees who have access to your personal data are required to adhere to this Policy, and all third-party service providers are requested by WOW Payments to ensure appropriate safeguards are in place. In addition, contracts are in place with third-party service providers that have access to your personal data to ensure that the level of security and protective measures required in your jurisdiction are in place and that your personal data is processed only as instructed by WOW Payments.

3.3 We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, technical, and organizational safeguards that comply with applicable laws and regulations to protect your personal information from unauthorized access.

4. Ways we use your information

4.1 Lawful basis: We will only use your personal data when the law allows us to. Depending on the country in which you are in, we rely on the following legal bases to process your personal data:

• Where you have given us your consent to process your data – please note that when we are processing your personal data on the basis of consent, the applicable local regulations apply;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we have a legal obligation to process your personal data to comply with laws, regulations or court orders;
• Where it is necessary to fulfil our obligations under a contract with you;
• Where it is necessary to protect the vital interests of yourself or other individuals.

4.2 Purposes for which we will use your personal data: the ways we plan to use your personal data are described below. We have also identified what our legitimate interests are where appropriate.

• to carry out our obligations relating to your contract with us for the provision of payment services and multi-currency accounts.

Lawful basis for processing, including basis of legitimate interest:
It is necessary to fulfill our obligations under a contract.

• to provide you with information, products and services.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to keep our records up-to-date, decide which of our products and services may be of interest to you, to tell you about them and deliver them to you) Where you’ve consented for us to process your personal data in a certain way.

• to comply with any applicable legal and/or regulatory requirements, including to respond to requests from public and government authorities, including public and government authorities outside your country of residence, upon demonstration of lawful authority, and to comply with court orders from the relevant jurisdiction.

Lawful basis for processing, including basis of legitimate interest:
Legal obligation
Necessary to fulfill our obligations under a contract
Legitimate interest (to be efficient about how we meet our legal obligations and to comply with regulations that apply to us)
Credit protection, including the provisions of the relevant legislation*
The regular exercising of rights in judicial, administrative or arbitral proceedings*

• to prevent and detect crimes, including fraud and financial crime.

Lawful basis for processing, including basis of legitimate interest:
Legal obligation
Legitimate interest (to detect and prevent criminal activity in connection with our Services and improve how we manage instances of suspected financial crime)
Credit protection, including the provisions of the relevant legislation*

• to notify you about changes to our Services and send you other administrative information.

Lawful basis for processing, including basis of legitimate interest:
Legal obligation
Legitimate interest (to provide you with a good customer service and keep you up-to-date with new developments)
Necessary to fulfil our obligations under a contract

• as part of our efforts to keep our Services safe and secure

Lawful basis for processing, including basis of legitimate interest:
Legal obligation
Legitimate interest (protecting our customers and ourselves from loss or harm)
Necessary to fulfill our obligations under a contract.

• to administer our Services and for internal operational, planning, audit, troubleshooting, data analysis, testing, research, statistical and survey purposes

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to keep our records up to date, efficiently fulfill our legal and contractual duties, carry out our administrative operations, and develop new and existing products and services)

• to undertake system or product development, including helping third-party suppliers improve the services they provide to us, to improve our Services, and to ensure that they are presented in the most effective manner.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to develop existing and new products and services and to efficiently meet our legal and contractual obligations)

• to allow other WOW Payments customers to request or send money to you through our services when providing information that matches your phone number or email address.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to provide an efficient and innovative service to our customers)
Necessary to fulfill our obligations under a contract.

• to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to market our products and services in the most efficient manner)
Where you’ve consented for us to process your personal data in a certain way.

• to allow you to participate in interactive features of our Services when you choose to do so.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to provide an efficient and innovative service to our customers)
Where you’ve consented for us to process your personal data in a certain way.

• to use your email address to provide you with information about other similar goods and services we offer.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to market our products and services)
Where you’ve consented for us to process your personal data in a certain way.

• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.

Lawful basis for processing, including basis of legitimate interest:
Where you’ve consented for us to process your personal data in a certain way.

• to take steps to recover amounts owed to us, including via insurance claims, and to allow us to pursue available remedies or limit damages that we may sustain.

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to protect our assets)
Credit protection, including the provisions of the relevant legislation*

• to allow a third party or a financial institution that sent money to recover money received by you in error or due to fraud.

Lawful basis for processing, including basis of legitimate interest:
Legal obligation
Legitimate interest (to allow third parties to recover funds)

• to enforce our Customer Agreement with you

Lawful basis for processing, including basis of legitimate interest:
Legitimate interest (to protect our assets)

• on rare occasions, to help safeguard our customers, employees, or other individuals by notifying the emergency services.

Lawful basis for processing, including basis of legitimate interest:
Vital interest.

5. Disclosure of your personal data

5.1 We may share your personal data with the following third parties:

• affiliates, business partners, suppliers, and sub-contractors for the performance and execution of any contract we enter into with them or you and to help them improve the services they provide to us or for any service we are required to perform by banks partner or regulations ;
• advertisers and advertising networks to select and serve relevant adverts to you and others;
• analytics and search engine providers that assist us in the improvement and optimization of our site;
• in the event that we sell any of our business or assets or combine with another organization, in which case we may disclose your personal data to the prospective buyer of such business or assets or prospective organization with which our business or assets may be combined;
• limited information is sent to payment beneficiaries when you initiate a payment transaction;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements, or to protect the rights, property, or safety of WOW Payments, our customers, our employees or others;
• to prevent and detect fraud or crime and to assist us in conducting or cooperating with investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so. Please note that if we, or a fraud prevention agency, determine that a fraud or money laundering risk is posed, we may refuse to provide the services requested, or we may stop providing existing products and services to a customer. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services.
• in response to a subpoena, warrant, court order, properly constituted police request or as other WOW Payments required by law;
• to assess financial and insurance risks;
• to recover a debt or in relation to your insolvency or to allow a party or a financial institution that sent money to recover money received by you in error or due to fraud;
• to develop customer relationships, services, and systems; and
• if you consent to share your details when using our Services

5.2 If your discoverability feature is enabled, WOW Payments customers can search for you via your nickname or the email address or phone number registered to your WOW Payments account. You can manage this discoverability feature under your account settings. You can also generate a link to share with any users to make it easier to send and receive money.

5.3 If you would like further information about who we have shared your data with or to be provided with a list specific to you, you can request this by writing to support@wowbrand.com.

6. Sharing and storing your personal data

6.1 While our main processing centres are in the US, we may transfer your data to and store it in countries outside of your jurisdiction, which do not offer an equivalent level of protection to your country. It may also be processed by staff operating outside of your jurisdiction. Such staff may be engaged in activities that include the fulfilment of your payment order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

6.2 In the above cases, we ensure that appropriate safeguards, including Standard Contractual Clauses and/or International Data Transfer Agreements, are in place. A copy of these documents can be provided by sending a request to support@wowbrand.com.

7. Cookies

WOW Payments Website uses cookies to track traffic coming to our site. We do not collect personal data such as name, age, telephone number, e-mail, or mailing address. Cookies will also be used to identify a person who chooses to register on our site. If you choose to register on our site and are given a password, choose to give gifts online, or choose to enroll in our e-mail subscription services, we will identify you with cookies. You will always have a chance to opt out at any time.

8. Data retention

8.1 We will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it. As a regulated financial institution, WOW Payments is required by law to store some of your personal and transactional data beyond the closure of your account with us. We only access your data internally on a need-to-know basis, and we’ll only access or process it if absolutely necessary.

8.2 We will always delete data that is no longer required by the relevant law or jurisdiction in which we operate. We do this automatically, so you don’t need to contact us to ask us to delete your data. Deletion methods include shredding, destruction, and secure disposal of hardware and hard-copy records, and deletion or overwriting of digital data.

9. Your rights

9.1 Laws applicable in your jurisdiction may grant you certain rights regarding the information we hold about you. If you have any questions in relation to our use of your personal information, contact us at support@wowbrand.com.

9.2 Your exercise of these rights may be subject to certain exemptions, including to safeguard the public interest (including the prevention or detection of crime), where it is in our interests (including the maintenance of legal privilege), and where the rights of other persons are involved (including where your request relates to information about other individuals).

9.3 We may need to retain certain information for record-keeping purposes and to comply with our obligations under applicable laws and regulations, including but not limited to our anti-money laundering obligations, and/or to complete any transactions that you began prior to requesting a change or deletion.

9.4 You will not normally have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee where permitted by local laws or if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9.5 We may need to request specific information from you to help us confirm your identity and your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.6 If you no longer want to receive marketing-related emails from us, you may opt-out by following the instructions in any such email. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt-out, we may still send you important administrative messages from which you cannot opt-out.

9.7 If you would like to make a request, the best way to do so would be to contact us at the contact details listed at the bottom of this policy.

9.8 Subject to some country-specific variations, you have the right to:

• Request a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.
• Ask us to delete personal data where there is no good reason for us to continue to process it. You may also have the right to ask us to delete your personal data where (i) you have successfully exercised your right to object to processing (see below), (ii) where we may have processed your personal data unlawfully or (iii) where we are required to delete your personal data to comply with local law. We may not always be able to comply with your deletion request for specific legal reasons, which will be notified to you, if applicable, in our response to your request, including financial regulations that may require us to hold your personal data for a period after the closure of your account.
• Withdraw your consent for us to process data, where our lawful basis for processing is based on that consent. Note that withdrawal of consent does not affect the lawfulness of processing which may have taken place prior to withdrawal of consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
• Request us to cease direct marketing to you, or profiling you for the purpose of direct marketing, by contacting us or adjusting your notification preferences in the settings section of your account.
• Where we use wholly automated decision making-processes, request that we provide information about the decision-making methodology and ask us to verify that an automated decision that results in a legal impact on you has been made correctly. We may reject the request, as permitted by applicable law, including when providing the information would result in a disclosure of a trade secret or would interfere with the prevention or detection of fraud or other crime. However, generally in these circumstances we will verify that the algorithm and source data are functioning as anticipated without error or bias or, if required by law, to adjust the processing.
• Object to any processing based on the legitimate interests ground, when there is something about your particular situation where you feel processing on this ground impacts your fundamental rights and freedoms.
• Ask us to suspend the processing of your personal data in the following situations: (i) if you want us to determine the data’s accuracy; (ii) where our processing of the data is unlawful but you do not want us to delete it at this time; (iii) where you wish us to retain the data even if we no longer require it because you need it to establish, exercise or defend legal claims; or (iv) you have objected to us using your data but we need to confirm whether or not we have to override legitimate grounds to continue using it.
• Request the transfer of your personal data to a third party or yourself. We will provide you or your chosen third party with the personal data you provided to us in a structured, commonly used, machine-readable format. This right applies only to information where we used the information to perform a contract with you or where you initially consented for us to use it.

10. Managing communications

As part of providing the Services, WOW Payments (whether directly or through a third party), may send you:

Marketing communications: Depending on the nature of our relationship and the Services being used, we may send you marketing and other promotional communications for new or existing Services that we think you might be interested in. These marketing communications may include marketing text messages if you have opted in to receiving them. You can opt out of or unsubscribe from any marketing communications by following the instructions in those messages, by changing your communications preferences within your account or through your device. You can also opt out by contacting us at support@wowbrand.com.  Opting out of one communication will not necessarily opt you out of all marketing communications.  Please note that you may still receive certain non-marketing communications after opting out. These messages may include transaction-specific communications, messages as part of a loyalty program or account-specific communications. If you are located outside the United States, we will not send you direct marketing communications without your opt-in consent or as otherwise permitted under the applicable law. 

11. California – your rights

If you are a California resident:

• You may have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your personal data, including:
  • The right to be informed of the personal data we collect, use, and process for purposes listed in section 4. Further detail on:
    • the categories of personal data collected,
    • the sources from which we collect it,
    • the business or commercial purposes of collection,
    • as well as the categories of third parties to whom we disclose personal data, are described within this Privacy Policy, as supplemented by WOW Payments Consumer Privacy Notice. 
  • The right to request the specific pieces of personal data that we have collected about you in the twelve (12) months preceding your request;
  • The right to request deletion of your personal data that we collected;
  • The right to correct any inaccurate information that we hold about you;
  • The right to limit the use of your sensitive personal information to only that which is necessary for providing products or services;
  • The right to opt-out of the sale or sharing of personal information, however please note that WOW Payments does not engage in the sale of personal information as contemplated by the CCPA. As detailed in this Privacy Policy, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information; and
  • The right not to be discriminated against for exercising any of these rights.

• You should be aware that this section does not apply to:
  • Personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act and its implementing regulations, the California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994; or
  • Other information subject to a CCPA exception.
• “Shine the Light” and “Eraser” Laws: you may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
• If you would like to make a request, please submit it in writing to support@wowbrand.com. We are obliged to verify your identity and that you are authorized to receive this information before fulfilling your request.

12. Other Jurisdictions

You may also have certain rights regarding the information we hold about you under other data protection and privacy laws. Please contact us at support@wowbrand.com for more information.

13. Third-party links

Our Services may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility for them, so if you follow a link, check these policies before you submit any personal data to these websites.

14. Changes to our Privacy Policy

To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Policy at any time by posting a revised version on this website. To stay up to date on any changes, check back periodically.

15. Contact

15.1 Please send any questions, comments or requests about this Policy to our privacy team at support@wowbrand.com, where you can also contact our Data Protection Officer. You can also write to us or our Data Protection Officer at our registered office that applies to you, as listed in the Appendix.

15.2 If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws, as listed in the Appendix

Country or Region	Entity	Registered Office and Details	Data Protection Authority
USA	TOT Payments Partners, LLC (DBA WOW Payments)	40 Exchange PI, Suite 1607, New York, NY 10005 support@wowbrand.com Phone Number: +1-855-500-8111	Federal Trade Commission (FTC) www.ftc.gov