Your privacy is very important to us. This privacy policy (“Privacy Policy”) is provided by 3Wire LLC and its affiliates (collectively, “3Wire”, “us”, “we”, or “our”) and sets forth the policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of your personal information. We may change this Privacy Policy from time to time without prior notice to you. Any changes will be effective immediately upon posting to our Site.
The categories of personal data we may collect include names, addresses or other contact details, telephone numbers, account numbers, nationality, tax identification number, date of birth, place of birth, copies of identification documents, bank account details, information about assets or net worth, credit history, and/or other sensitive information.
We may collect personal data about you through (i) information provided directly to us by you or another person on your behalf; (ii) information we obtain through or in connection with the provision of products and services; (iii) through our websites; or (iv) recording and monitoring of electronic communications with you.
We also may receive your personal information from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
We may process your personal data for the purposes of administering the relationship between you and us (including communications and reporting), direct marketing of our products and services, monitoring and analyzing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities with competent jurisdiction over our business). Your personal data will be processed in accordance with Data Protection Law and may be processed with your consent, upon your instruction, or for any of the purposes set out herein, including where a third party or we consider there to be any other lawful purpose to do so.
Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us being unable to provide services to you. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.
We may disclose information about you to our affiliates or third parties for the purpose of providing services to us (e.g., accountants, professional advisors, IT, communications providers) for our everyday business purposes, such as to enable that we can provide services to you or to respond to court orders and legal investigations. We will also release information about you if you direct us to do so.
We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us as described below (see “Who to contact about this Privacy Policy”). We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.
We may record and monitor telephone conversations and electronic communications with you for the purposes of (i) ascertaining the details of instructions given in connection with the delivery of our services to you; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.
We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the Data Protection Law. How long we will hold your personal data will be determined by: (a) the purpose for which we are using it - we will need to keep the data for as long as it is necessary for that purpose; and (b) legal and regulatory obligations - laws or regulation may set the minimum period for which we have to keep your personal data. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or delete it if it no longer serves any purpose to us.
To protect your personal information from unauthorized access and use, we apply organizational and technical security measures in accordance with Data Protection Law. These measures include computer safeguards and secured files and buildings. We will notify you of any material personal data breaches affecting you in accordance with the requirements of the Data Protection Law.
Personal data may be transferred outside your home country, such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by your own. In such cases, we will take appropriate measures to ensure your personal information is handled as described in this Privacy Policy.
Federal law gives you the right to limit only the following information sharing: (1) sharing with affiliates for everyday business purposes information about your creditworthiness; and (2) sharing with non-affiliates for the purpose of marketing products or services to you. If you would like to limit any of the foregoing sharing purposes, please contact us in writing at the address below.
You may contact us at any time to limit our sharing of your personal information.
Where applicable, California residents have the following privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”). For the purposes of this section of the policy, “Personal Information” means any data that defines, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, which is in the possession of, or is likely to come into the possession of, any 3Wire entity.
These rights include, to the extent required by the CCPA and subject to verification and any applicable exceptions:
We will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. Your request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to Personal Information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.
Please note that 3Wire does not, and will not, sell Personal Information collected about you.
You can exercise your rights by contacting us using the details listed below under the section titled “Who to Contact about this Privacy Policy.”
If you have any questions about our Privacy Policy, you should contact our compliance department by email at compliance@3wp.com or by mail at the following address:
3Wire Partners
ATTN: Compliance Department
1717 Pennsylvania Avenue NW, Suite 300
Washington, D.C. 20006