בטעינה
מסמך זה זמין באנגלית בלבד.
Legal
This Privacy Policy explains how WYA collects, uses, stores, shares and protects personal information obtained through the WYA website, the Individuals membership-interest form and related enquiries.
Last updated:
WYA LIMITED (“WYA”, “we”, “us” or “our”) is the controller of personal information collected through this website, the Individuals membership-interest form and related enquiries.
WYA LIMITED is registered with the UK Information Commissioner’s Office (ICO) as a data protection fee payer. Our registration reference is ZC278284.
WYA, short for Wherever You Are, develops technology, AI intelligence and international connectivity for a global network of regulated banking partners.
We may collect information that you provide when you contact us, submit an enquiry, request information, express interest in membership or a career with WYA, or otherwise communicate with us.
For contact enquiries, we collect your name, email address, country selected from the country list, enquiry type and message. You may also choose to provide your organisation, role, LinkedIn profile or other information in your message. We retain a record of when the form was submitted and the information-use statement displayed with the form.
For the Individuals membership-interest form, we collect your name, email address, one required and up to two optional countries selected from the country list in priority order, confirmation that you are aged 18 or over, and records showing when the form was submitted and consent was provided.
This policy covers this website and its forms. We do not collect account connections or transaction histories through these forms. Any future application or connected banking service would explain separately what information it uses, why it is needed and the choices available to you.
The website and its service providers may also process limited technical information needed to operate and secure the website. This may include your IP address, device and browser information, pages requested, referring pages and timestamps.
When a form is submitted, the IP address associated with the request may be processed for bot detection, security verification and rate limiting. Raw IP addresses are not stored as part of the encrypted form submission.
WYA does not currently use analytics cookies.
Please do not provide bank account credentials, payment card details, government identity documents, health information or other sensitive personal information through our website forms.
We use contact-enquiry information to:
We use Individuals membership-interest information to:
Submitting the membership-interest form does not grant membership or constitute an application for a financial product or service. We do not use this information to determine eligibility for a financial product or to make lending, investment or other financial decisions about you.
We do not use this website to provide financial services.
We process contact enquiries where necessary for our legitimate interests in responding to enquiries and managing prospective relationships, or to take steps at your request in connection with a potential contractual relationship.
We rely on consent to manage Individuals membership interest and send relevant updates.
We process limited technical information where necessary for our legitimate interests in operating, protecting and securing the website.
We may also process personal information where necessary to comply with a legal obligation.
Where we rely on legitimate interests, we consider and balance those interests against your rights and freedoms.
When you submit the Individuals membership-interest form, we record your confirmation that you are aged 18 or over and your consent to receive relevant updates from WYA.
You may withdraw your consent at any time by using the unsubscribe link in an email or contacting privacy@wya.uk. Withdrawing consent does not affect processing that took place before it was withdrawn.
If you withdraw your consent, we will stop sending the communications covered by that consent. We may retain limited information on a suppression list so that we can record and respect your request not to receive further communications.
We may share personal information with service providers that help us:
These service providers may include hosting, security, cloud infrastructure, database, email, relationship-management and professional-services providers.
Forms protected by Cloudflare send technical information to Cloudflare for bot detection and security verification. This may include your IP address and information about your browser and device. Cloudflare’s Privacy Policy explains its processing. Personal details submitted through our live forms are encrypted before storage in Supabase.
Where appropriate and lawful, we may also share personal information with advisers, regulators, authorities or other parties involved in a prospective relationship, transaction, legal process or compliance matter.
We do not provide Individuals membership-interest information to financial institutions or technology companies for their own independent marketing.
We do not sell personal information collected through this website.
Personal information may be transferred to or accessed by service providers and other recipients outside the United Kingdom.
Where required by applicable data protection law, we use appropriate safeguards, such as contractual protections, adequacy regulations or another recognised transfer mechanism.
Contact privacy@wya.uk for information about international transfers, the safeguards that apply and how to obtain a copy of those safeguards.
We keep enquiry records while handling your enquiry and any resulting relationship. We keep membership-interest records while administering your interest and the updates you have requested. When deciding how long to retain a record, we consider whether the matter remains active, whether you have withdrawn consent, and whether a limited record is needed to meet a legal obligation, establish or defend a claim, demonstrate consent or respect an unsubscribe request.
We review these records against our retention criteria and delete or anonymise personal information that is no longer needed. Information retained solely to comply with a legal obligation, address a dispute or respect an unsubscribe request is restricted to that purpose.
If you withdraw consent, we will stop the relevant communications and may retain only the limited information needed to record and respect your request.
Depending on the law that applies to our processing and the circumstances, you may have rights to:
You may object to direct marketing at any time. If you do, we will stop using your personal information for that purpose.
To exercise your privacy rights, please contact us using the details below. We may need to verify your identity before responding.
We use reasonable technical and organisational measures designed to protect personal information.
Website form submissions are encrypted before storage. Access to the underlying systems and encryption credentials is restricted.
However, no website, transmission or storage system can be guaranteed to be completely secure.
You must be aged 18 or over to submit the Individuals membership-interest form. We ask you to confirm this when submitting your details, but we do not ask for your date of birth through the form.
The membership-interest form is not directed at children, and we do not knowingly collect personal information from anyone under 18 through it. If we learn that information has been provided by someone under 18, we will take reasonable steps to delete it.
We do not use information collected through the Individuals membership-interest form to make solely automated decisions that produce legal or similarly significant effects for you.
We may update this Privacy Policy when our practices or legal requirements change. The latest version and its last-updated date will appear on this page. Where applicable law requires notice of a material change, we will provide that notice before the change takes effect.
For privacy questions, consent withdrawals or requests concerning your personal information, please contact privacy@wya.uk.
Where required by applicable law, we will respond in accordance with the relevant data protection legislation.
Where UK data protection law applies, you may complain to the Information Commissioner’s Office without contacting us first. Where Australian privacy law applies, you can complain to us at privacy@wya.uk and, if your concern is not resolved, raise it with the Office of the Australian Information Commissioner. You may also have complaint rights under applicable United States law.
This section applies if you are in the United States. It supplements the rest of this Privacy Policy.
Personal information we collect. In the past 12 months, we have collected the following categories of personal information through this website:
We collect this information directly from you and from your device when you use the website. We use it for the purposes described in section 3, disclose it to the categories of service providers described in section 6 and keep it as described in section 8.
No sale or sharing. We do not sell personal information, and we do not share it for cross-context behavioural advertising (targeted advertising). We have not done so in the past 12 months, and we do not knowingly sell or share the personal information of anyone under 16. We do not ask for sensitive personal information and do not use it to infer characteristics about you.
Your requests. Whichever state you live in, you may ask us to:
To make a request, email privacy@wya.uk. We will verify your identity before responding, usually by asking you to confirm details from the email address you used with us. You may use an authorised agent; we may ask for proof of the agent’s authority and ask you to confirm your identity directly. We aim to respond within 45 days. If your state gives you a right to appeal our decision, you may appeal by replying to our response, and we will tell you the outcome and how to contact your state attorney general. We will not discriminate against you for exercising any of these rights.
Do Not Track and Global Privacy Control. Our website does not respond to browser Do Not Track signals, because there is no common standard for them. Because we do not sell or share personal information or use targeted advertising, there is currently nothing for a Global Privacy Control signal to opt out of; if that changes, we will treat a Global Privacy Control signal as a valid opt-out request. We do not allow third parties to use our website to track your activities over time and across other websites for advertising.
California. California residents may ask whether we have disclosed personal information to third parties for their own direct marketing purposes. We do not make such disclosures.
Where your information is processed. WYA LIMITED is based in the United Kingdom. Personal information submitted through our website forms is stored in the United Kingdom. Service providers may process or access information outside the United Kingdom as described in section 7.
Future financial services. This website does not offer financial products or services. If WYA or a partner bank offers financial products or services in the United States, those services will have their own privacy notice.
Complaints. If you have a concern, please contact us first at privacy@wya.uk. You may also contact the consumer protection office of your state attorney general.