Update Wire Privacy Policy

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Wire/Privacy Policy.md

@@ -1,40 +1,6 @@
-June 30, 2020
+### 1\. Our Privacy Commitment
 
-### Table of contents
-
-1[Our Privacy Commitment](#privacy-1)
-
-2[Conversation content](#privacy-2)
-
-3[Logs files](#privacy-3)
-
-4[Profile Information that you provide](#privacy-4)
-
-5[Data relevant to payment](#privacy-5)
-
-6[Processing of data in response to requests](#privacy-6)
-
-7[Newsletters](#privacy-7)
-
-8[Additional technical data](#privacy-8)
-
-9[Address book data](#privacy-9)
-
-10[Usage data](#privacy-10)
-
-11[Support cases](#privacy-11)
-
-12[Third parties / data transfer to third countries](#privacy-12)
-
-13[Your rights as a data subject](#privacy-13)
-
-14[Notification of changes](#privacy-14)
-
-15[Terms of Use](#privacy-15)
-
-### 1Our Privacy Commitment
-
-Wire Swiss GmbH ("**Wire**" "**we**" "**us**"), as the responsible party within the meaning of data protection law, is committed to protecting your data. Wire does not rent or sell your data to third parties. Your data is also not used for targeted ads, or any other kind of profiling. This Privacy Policy informs you about how we process your data when you use the app offered by us and/or additional Wire products (together "**Wire services**") and what rights you have as a data subject towards us. Unless the context indicates otherwise, any reference to "you", "your" or "yourself" in this Privacy Policy includes the respective user of a team management functionality, the respective team admin and the respective team member of the Wire Services (as defined in our Terms of Use).
+Wire Swiss GmbH (“Wire” “we” “us”), as the responsible party within the meaning of data protection law, is committed to protecting your data. Wire does not rent or sell your data to third parties. Your data is also not used for targeted ads, or any other kind of profiling. This Privacy Policy informs you about how we process your data when you use the app offered by us and/or additional Wire products (together “Wire services”) and what rights you have as a data subject towards us. Unless the context indicates otherwise, any reference to “you”, “your” or “yourself” in this Privacy Policy includes the respective user of a team management functionality, the respective team admin and the respective team member of the Wire Services (as defined in our Terms of Use).
 
 Our contact details are:
 
@@ -45,7 +11,7 @@ email: [email protected]
 
 You can contact our Data Protection Officer (DPO) at [email protected]. You can address inquiries to them regarding your data, its protection and its treatment by Wire.
 
-### 2Conversation content
+### 2\. Conversation content
 
 All conversation content is encrypted with strong encryption on the sender’s device and is only decrypted on the recipient’s device (also known as end-to-end encryption). Wire doesn’t hold the decryption keys, and our software contains no backdoor. Your conversations are yours — Wire has no access to them. You may delete the content of the conversations on your device specifically and generally at any time.
 
@@ -55,94 +21,93 @@ Wire only temporarily stores encrypted messages on its servers and automatically
 
 The legal basis for the transmission and storage of conversations is Art. 6 Para. 1 lit. b) GDPR (fulfilment of contract).
 
-### 3Logs files
+### 3\. Logs files
 
-When you use Wire services, we may collect technical data, so-called "log files", with each access. The collection of log files serves the purpose of providing Wire services. The legal basis for the collection is Art. 6 § 1 b) DS-GVO (fulfilment of contract).
+When you use Wire services, we may collect technical data, so-called “log files”, with each access. The collection of log files serves the purpose of providing Wire services. The legal basis for the collection is Art. 6 § 1 b) DS-GVO (fulfilment of contract).
 
 Log files are kept for a maximum of 72 hours, and only to facilitate troubleshooting, improve the service and prevent misuse. The legal basis for storage is Art. 6 § 1 f) GDPR (legitimate interest). Our legitimate interest is the trouble-free provision of the Wire services.
 
-### 4Profile Information that you provide
+### 4\. Profile Information that you provide
 
-When you create an account with Wire, we ask you to provide a name and a mobile phone number or email address ("**Profile Information**"). The Profile Information you provide will be used for the purpose of providing Wire services and may be displayed to other Wire users when they search for you or connect to you through Wire services. If you have registered with a phone number, this information will not be displayed to other Wire users. If you registered with an email address, your email address may be visible to other users when using Wire Pro, depending on your preferences. We store your profile information only for the duration of your account usage. If you delete your account, we will delete your profile information immediately. You can change or delete your profile data at any time. The legal basis for the processing of your profile data is Art. 6 § 1 b) GDPR (fulfilment of contract).
+When you create an account with Wire, we ask you to provide a name and a mobile phone number or email address (“Profile Information”). The Profile Information you provide will be used for the purpose of providing Wire services and may be displayed to other Wire users when they search for you or connect to you through Wire services. If you have registered with a phone number, this information will not be displayed to other Wire users. If you registered with an email address, your email address may be visible to other users when using Wire Pro, depending on your preferences. We store your profile information only for the duration of your account usage. If you delete your account, we will delete your profile information immediately. You can change or delete your profile data at any time. The legal basis for the processing of your profile data is Art. 6 § 1 b) GDPR (fulfilment of contract).
 
-### 5Data relevant to payment
+### 5\. Data relevant to payment
 
-If you create a Team Admin account or Team Member account with Wire, we may ask you for additional information for billing purposes and may share that information with a billing provider ("**Data relevant to payment**"). In order to make purchases through Wire services using a Team Admin account, Team Admins must provide a payment method and may be required to provide additional information such as billing address, phone number, email address, and zip code if required for tax purposes or to complete billing. In addition, other types of information related to the specific transaction may be collected, such as transaction amount and duration. The legal basis for the processing of the above-mentioned data is Art. 6 § 1 b) GDPR (fulfilment of contract), if we collect and store data for tax reasons, the legal basis is Art. 6 § 1 c) GDPR (fulfilment of a legal obligation). We delete this data within 6 months after our contract with you is terminated or after the expiry of any existing legal obligation to retain data.
+If you create a Team Admin account or Team Member account with Wire, we may ask you for additional information for billing purposes and may share that information with a billing provider (“Data relevant to payment”). In order to make purchases through Wire services using a Team Admin account, Team Admins must provide a payment method and may be required to provide additional information such as billing address, phone number, email address, and zip code if required for tax purposes or to complete billing. In addition, other types of information related to the specific transaction may be collected, such as transaction amount and duration. The legal basis for the processing of the above-mentioned data is Art. 6 § 1 b) GDPR (fulfilment of contract), if we collect and store data for tax reasons, the legal basis is Art. 6 § 1 c) GDPR (fulfilment of a legal obligation). We delete this data within 6 months after our contract with you is terminated or after the expiry of any existing legal obligation to retain data.
 
-### 6Processing of data in response to requests
+### 6\. Processing of data in response to requests
 
 If you send us an inquiry about our products as an interested party, we collect the information you provide, such as your name, e-mail address or other contact information you provide us with. We process this information for the purpose of answering your inquiry. The legal basis for the processing of your above-mentioned personal data is Art. 6 § 1 b) GDPR (contract initiation). We delete your data after the processing of your inquiry is completed.
 
 If you have provided an e-mail address, Wire may send you e-mails to inform you of important changes (e.g. to confirm your e-mail address or to inform you that a new device has been added to your account). This is to help us provide you with a more secure experience with your account. The legal basis for the processing of this personal data is Art. 6 § 1 b) GDPR (fulfilment of contract).
 
-### 7Newsletters
+### 7\. Newsletters
 
-If you have given us your consent for the purpose of receiving our newsletter with information about Wire's offers and products by e-mail, Wire will process your e-mail address and name to send you the newsletter. The legal basis for the processing of your data is your consent in accordance with Art. 6 § 1 a) GDPR. You can unsubscribe from the newsletter at any time. For this purpose there is a link in every newsletter. We only store your data for this purpose for as long as the newsletter subscription is active.
+If you have given us your consent for the purpose of receiving our newsletter with information about Wire’s offers and products by e-mail, Wire will process your e-mail address and name to send you the newsletter. The legal basis for the processing of your data is your consent in accordance with Art. 6 § 1 a) GDPR. You can unsubscribe from the newsletter at any time. For this purpose there is a link in every newsletter. We only store your data for this purpose for as long as the newsletter subscription is active.
 
-### 8Additional technical data
+### 8\. Additional technical data
 
 Wire stores additional technical data (such as the type of device through which you authorized the Wire application) to be able to route data between user devices. The Wire service is designed to keep additional technical data to the minimum required to operate the service.
 
 More information about additional data can be found in the Privacy Whitepaper and the Security Whitepaper.
 
-### 9Address book data
+### 9\. Address book data
 
 You are free to give Wire services access to your address book contacts. This is for the purpose of communicating with other users of Wire services. In this case, only hashed phone numbers are processed volatilely. The rest of your address book content is never uploaded to our servers.
 
-### 10Usage data
+### 10\. Usage data
 
 We process individual data about the use of Wire services in order to create anonymous usage statistics and crash logs. Insofar as personal data are processed for this purpose and your consent is required for processing, we will only process your data after you have given your consent (Art. 6 § 1 a) GDPR). Insofar as personal data is processed for this purpose and your consent is not required for processing, we process your data on the basis of legitimate interest (Art. 6 § 1 f) GDPR). Our legitimate interest is the trouble-free provision of the Wire services. You can prevent the processing of your data for these purposes at any time (see FAQ).
 
-### 11Support cases
+### 11\. Support cases
 
 When you contact Wire Customer Service for a support request, we process the personal information you provide in the support request for the purpose of processing your support request. The legal basis for the processing of your data for the processing of the support request is Art. 6 § 1 f) GDPR (legitimate interest). Our legitimate interest is to provide a support service for our customers. We delete your personal data processed for the processing of the support request after the processing of your request has been completed.
 
-### 12Third parties / data transfer to third countries
+### 12\. Third parties / data transfer to third countries
 
 To provide Wire services, Wire uses the services of the following third-party providers:
 
-| Name | Function of the third party | Jurisdiction |
-| --- | --- | --- |
-| Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855 Luxemburg | Infrastructure-as-a-Service | Luxemburg |
-| Zeta Project Germany GmbH, Rosenthaler Str. 40, 10178 Berlin, Germany | Development of the Wire services | Germany |
+Name Function of the third party Jurisdiction  
+Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855 Luxemburg Infrastructure-as-a-Service Luxemburg  
+Zeta Project Germany GmbH, Rosenthaler Str. 40, 10178 Berlin, Germany Development of the Wire services Germany
 
 Wire undertakes to select only third-party providers for the provision of Wire services in the EU and/or Switzerland.
 
 For the processing of personal data of business prospects and users of business accounts, Wire makes use of services of the following third-party providers:
 
-| Name | Function of the third party | Jurisdiction |
-| --- | --- | --- |
-| Marketo | Sending of emails | USA |
-| Salesforce | CRM services | USA |
-| Clearbit | CRM services | USA |
-| DocuSign | Signature management | USA |
-| Stripe | Payment services | USA |
-| Zendesk | Support ticketing | USA |
-
-Wire will disclose personal data to third parties only if and to the extent necessary to provide the third party service (e.g., to respond to a support request), if required by law or legal process, or if necessary to enforce the Terms of Use and/or protect Wire's rights.
+Name Function of the third party Jurisdiction  
+Marketo Sending of emails USA  
+Salesforce CRM services USA  
+Clearbit CRM services USA  
+DocuSign Signature management USA  
+Stripe Payment services USA  
+Zendesk Support ticketing USA  
+Wire will disclose personal data to third parties only if and to the extent necessary to provide the third party service (e.g., to respond to a support request), if required by law or legal process, or if necessary to enforce the Terms of Use and/or protect Wire’s rights.
 
 Wire will not disclose your data to public authorities unless Wire is obliged to do so under Swiss law.
 
 In addition, to the extent permitted by data protection law, Wire may disclose your personal data to third parties if we (or our affiliates) are acquired by that third party with any of our assets or voting securities (or those of our affiliates) or if we are otherwise involved in a transaction with similar financial effect. In such a situation, we will use reasonable efforts to require the third party to process your data in accordance with this Privacy Policy in relation to your personal data. If your personal data is subsequently used in a manner different from that described in this Privacy Policy, we ask the third party to notify you in advance.
 
-To the extent that Wire transfers personal data to third parties located outside the European Economic Area (EEA) (see also the overview of third party providers above), Wire will ensure that (i) the third party is located in a state that has been recognized by the EU Commission as having an equivalent level of data protection or or/and (ii) Wire has concluded "standard data protection clauses" with the third party within the meaning of Art. 46 § 2 c) GDPR or/and (iii) there is another guarantee within the meaning of Art. 46 or exception under Art. 49 GDPR. If you use third-party services such as YouTube, Spotify, Giphy etc. via the Wire application, all data that you share with these services is subject to their privacy policies.
+To the extent that Wire transfers personal data to third parties located outside the European Economic Area (EEA) (see also the overview of third party providers above), Wire will ensure that (i) the third party is located in a state that has been recognized by the EU Commission as having an equivalent level of data protection or or/and (ii) Wire has concluded “standard data protection clauses” with the third party within the meaning of Art. 46 § 2 c) GDPR or/and (iii) there is another guarantee within the meaning of Art. 46 or exception under Art. 49 GDPR. If you use third-party services such as YouTube, Spotify, Giphy etc. via the Wire application, all data that you share with these services is subject to their privacy policies.
 
-### 13Your rights as a data subject
+### 13\. Processing of data in response to requests
 
 As a data subject within the meaning of the GDPR, you have the following rights in relation to Wire:
 
-You have the right to obtain information about the personal data that we store about you (Art. 15 GDPR), the right to correction (Art. 16 GDPR), deletion (Art. 17 GDPR) and restriction of the processing of your personal data (Art. 18 GDPR). You are also entitled to exercise your right to data transferability (Art. 20 GDPR).
+**You have the right to obtain information about the personal data that we store about you (Art. 15 GDPR), the right to correction (Art. 16 GDPR), deletion (Art. 17 GDPR) and restriction of the processing of your personal data (Art. 18 GDPR). You are also entitled to exercise your right to data transferability (Art. 20 GDPR).**
 
-**You also have the right to object to the processing of personal data concerning you which is carried out in accordance with Art. 6 § 1 e) or f) GDPR. Unless we are still legally obliged or entitled to process your personal data, we will no longer process your personal data (Art. 21 § 1 GDPR). If you object to the use of your data for the purposes of direct marketing, we will no longer process the personal data concerned for these purposes (Art. 21 § 2 GDPR).**
+You also have the right to object to the processing of personal data concerning you which is carried out in accordance with Art. 6 § 1 e) or f) GDPR. Unless we are still legally obliged or entitled to process your personal data, we will no longer process your personal data (Art. 21 § 1 GDPR). If you object to the use of your data for the purposes of direct marketing, we will no longer process the personal data concerned for these purposes (Art. 21 § 2 GDPR).
 
 You may revoke any declarations of consent you have given at any time (Art. 7 § 3 GDPR). Revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until revocation. You have the right to complain to a supervisory authority.
 
 No automated decision making, including profiling, pursuant to Article 22 § 1 and § 4 GDPR by Wire takes place.
 
-### 14Notification of changes
+### 14\. Notification of changes
 
 This Privacy Policy may change from time to time. We will make the revised Privacy Policy available through the Apps and post a revised version of this Privacy Policy on the website. Please check the Privacy Policy regularly to be informed of any changes.
 
-### 15Terms of Use
+### 15\. Terms of Use
+
+Please read the Terms of Use governing the use of the Site and the Service, as they also govern the terms of this Privacy Policy.
 
-Please read the Terms of Use governing the use of the Site and the Service, as they also govern the terms of this Privacy Policy.
+* * *