MyeWire collects some Personal Data from its Users in order to provide them with its Services.
Types of Data collected
Among the types of Personal Data that MyeWire collects, by itself or through third parties, there are: First name, Last name, Date of Birth, Address, Nationality, Email address, Mobile Phone Number, Identification document numbers and expiration dates, copies of Identification documents (for example, passport, national ID card, driving license and utility bill), Cookies and Usage Data
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using MyeWire.
Unless specified otherwise, all Data requested by MyeWire is mandatory and failure to provide this Data may make it impossible for MyeWire to provide its services. In cases where MyeWire specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or other tracking tools – by MyeWire or by the owners of third-party services used by MyeWire serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through MyeWire and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of MyeWire (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis for processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquiring with the Owner using the information provided in the contact section.
Retention time
In principle, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. However, as we are subject to regulatory requirements to retain information for specified minimum periods, we will not retain your personal information for longer than necessary.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained for at least 5 years or until such contract has been fully concluded.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
The purpose of processing
The Data concerning the User is collected to enable the Owner to provide its Services, as well as for the following purposes: Registration, Identification and Authentication, User database management, Handling payments, Contacting the User, Analytics, Tag Management, Hosting and backend infrastructure, Traffic optimization and distribution.
Users can find further detailed information about such purposes of processing and the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
By registering or authenticating, Users allow MyeWire to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, MyeWire will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (MyeWire)
The User registers by filling out the registration form and providing the Personal Data directly to MyeWire.
Personal Data collected: First name, Last name, Address, Email address, Mobile Phone Number
Direct authentication (MyeWire)
The User is authenticated by completing the User identification form and providing the Personal Data directly to MyeWire.
Personal Data collected: Date of Birth, Identification document numbers, copies of Identification documents (for example, passport, national ID card, driving license and utility bill)
Third-party providers that are web-based platforms and enable MyeWire to run detailed checks on people, companies, and ID documents in order to optimize business processes, reduce risk, and help ensure compliance.
Personal Data collected: First name, Last name, Address, Nationality, Email address, Mobile Phone Number, Date of Birth, Identification document numbers and expiration dates, copies of Identification documents (for example, passport, national ID card, driving license and utility bill)
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to MyeWire, as well as to track User activities through analytics features. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on MyeWire.
Mailing list or newsletter (MyeWire)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning MyeWire. Your email address might also be added to this list as a result of signing up to MyeWire.
Personal Data collected: Email address, First name and Last name.
Contact form (MyeWire)
By filling in the contact form with their Data, the User authorizes MyeWire to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: Email address, Mobile phone number, First name and Last name.
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data collected: Email address, First name and Last name
Payment processing services enable MyeWire to provide its Services and process payments by bank transfer or other means on behalf of its Users. To ensure greater security, MyeWire shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails or notifications concerning the payment.
Personal Data collected: First name, Last name, Address, Payment account information
Mailing list or newsletter (MyeWire)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning MyeWire. Your email address might also be added to this list as a result of signing up to MyeWire.
Personal Data collected: Email address, First name and Last name
Contact form (MyeWire)
By filling in the contact form with their Data, the User authorizes MyeWire to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: Email address, Mobile phone number, First name and Last name.
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data collected: Email address, First name and Last name
Place of processing: Privacy Policy
This type of service has the purpose of hosting Data and files that enable MyeWire to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of MyeWire. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Hetzner Online (Hetzner Online GmbH)
Hetzner Online is a professional web hosting provider and experienced data center operator.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Privacy Policy
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of MyeWire, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookie, Usage Data
Place of processing: Privacy Policy
This type of service helps the Owner to manage the tags or scripts needed on MyeWire in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookie, Usage Data
Place of processing: Privacy Policy
This type of service allows MyeWire to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between MyeWire and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
Cloudflare (Cloudflare, Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through MyeWire, i.e., communication between MyeWire and the User's browser, while also allowing analytical data from MyeWire to be collected.
Personal Data collected: Cookies; various types of Data as specified in the privacy policy of the service.
Place of processing: Privacy Policy
MEETING OUR LEGAL OBLIGATIONS
MyeWire has legal obligations to share your personal data with legal or other official bodies that include (without limitation):
- Central and local government, and where applicable, any EU/EEA or any other international government agency.
- HM Revenue & Customs, regulators and other domestic, EU/EEA or international tax authorities
- External audit companies
- Local, EU/EEA or international law enforcement or fraud prevention agencies (where applicable).
Personal Data collected: First name, Last name, Address, Nationality, Email address, Mobile Phone Number, Date of Birth, Identification document numbers and expiration dates, copies of Identification documents (for example, passport, national ID card, driving license and utility bill), Payment account information, account movements and balances.
The rights of Users
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract of which the User is part or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
MyeWire uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, MyeWire may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, MyeWire and any third-party services may collect files that record interaction with MyeWire (System logs) and use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
MyeWire does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within MyeWire and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top of the page.
Should the changes affect processing activities performed based on the User’s consent, the Owner shall collect new consent from the User, where required.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through MyeWire (or third-party services employed in MyeWire), which can include: the IP addresses or domain names of the computers utilized by the Users who use MyeWire, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using MyeWire who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of MyeWire. The Data Controller, unless otherwise specified, is the Owner of MyeWire.
MyeWire (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by MyeWire as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies
Small piece of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to MyeWire, if not stated otherwise within this document.