Protecting the privacy and safeguarding the personal and financial information of our clients and website visitors is one of our highest priorities. The following Privacy Statement explains how Wise Group LLC collects and protects your personal information. References to "Wise Group LLC" in this Privacy Statement include all Wise Group LLC companies and divisions.
By opening a Wise Group LLC account or by using Wise Group LLC websites, you give your consent to the collection and use of personal information by Wise Group LLC as explained in this Privacy Statement.
Collection of personal information
We collect your personal information directly from you and indirectly as a result of your relationship with us. Wise Group LLC may use the information collected from you to verify your identity and contact information, establish your trading account, issue you an account number and a secure password, maintain your account activity and contact you with account information, among other reasons. This information also helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you.
You directly provide us with the majority of information we collect. This information includes your contact details, including name, mailing address, telephone number and e-mail address, personal identification data we are required by law to collect, including your passport number and/or tax identification number, and information required by law to assess your trading experience and risk tolerance, including your annual income, net worth and available risk capital. We also collect demographic information when you open an account, including gender, birth date, occupation and employment status.
You provide us with this information by completing the account application and related documentation, by sending us an e-mail or by submitting information in response to a promotion or special offer.
The information we collect indirectly from you includes your Internet protocol ("IP") address, browser type, operating system, Internet service provider (ISP), time stamps and transaction history.
Should you close your account with us, Wise Group LLC will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other offers.
Sharing Personal Information with Wise Group LLC affiliates and Non-affiliated third parties
Wise Group LLC does not sell, license, lease or otherwise disclose your personal information to any affiliate or third party for any reason, except as described below.
Wise Group LLC may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer.
To help us improve our services to you, we may engage another business to help us carry out certain internal functions, such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a non-affiliated third party with client information from our database, including your name, address, phone number, and/or e-mail address, to help us analyze and identify client needs, notify clients of product and service offerings or conduct general marketing and market research for us.
Wise Group LLC also forges partnerships and alliances with non-affiliated third parties which offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, Wise Group LLC may share some personal information with these non-affiliated third parties.
We generally require that all non-affiliated third parties to which we provide your nonpublic personal information agree to keep your information confidential and use such information solely for the limited purpose for which we have engaged them, or as otherwise required by law. In addition, where offers are made to you by non-affiliated third parties, we generally require that they disclose that the offer is being extended because of your relationship with us. We also seek to ensure that these non-affiliated third parties maintain appropriate data security procedures to guard against unauthorized use of, or access to, your personal information.
When required by law, Wise Group LLC reserves the right to disclose your personal information to third parties or regulatory, law enforcement or other government authorities. We may also disclose your information to credit reporting or collection agencies, or when necessary to protect our rights or property.
The security of your personal information
We employ security software, systems and procedures to offer you a safe and secure trading environment and to protect your personal, financial and trading information.
When you open an account with us, you are issued a unique account number, User ID and a password. Only a limited number of Wise Group LLC employees who have a need to know this information will have access to your account number, UserID, and password. Remember that you are ultimately responsible for maintaining the secrecy of your account number, UserID and password. We strongly recommend that you do not disclose this information to anyone.
On our websites and online account application we use technology to encrypt information transmitted by or to you. We use certificate authority (CA) certificates to authenticate our websites and secure trading and customer-facing applications, allowing you to verify that you are connected to our websites.
Changes to this Privacy Statement and Opting Out
In the event Wise Group LLC materially changes this Privacy Statement, the revised Privacy Statement will promptly be posted to our websites. By opening an account with us, you are deemed to agree to accept posting of a revised Privacy Statement electronically on our website as actual notice to you.
Under certain circumstances, such as with respect to our sharing of your personal information with non-affiliated third parties, you may inform us that you would like to "opt out" by contacting us through the contact information listed below. Note that for joint accounts, an-opt out election made by one account owner of a joint account is applicable to all account owners of the joint account. An opt-out election must be made for each separate account you hold at Wise Group LLC.
Any dispute over our Privacy Statement is subject to this notice and the Wise Group LLC Customer Agreement. If you have any questions that this Privacy Statement does not address, please contact a Client Services representative.
Who we are
Wise Group LLC (“we”, “us”, “our”) is committed to protecting your privacy and maintaining the security of any personal information that we receive from you.
The purpose of this policy
The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. Companies are associated with us if they are our subsidiaries or we are both subsidiaries of the same corporate entity.
We are the controller of any personal information which you provide to us which means that we decide the purposes and means of the processing of that personal information.
If any provision or part-provision of this policy is or becomes invalid, illegal or unenforceable, it shall be deemed deleted, but that shall not affect the validity and enforceability of the rest of this policy.
How we obtain and store your information
We obtain your information through applications, emails, letters, telephone calls, SMS messages, cookies and conversations when registering for our services and during the course of our relationship (including information gained when you use our learning tools, demo accounts and trading simulators).
We may monitor or record phone calls with you and monitor (and maintain a record of) all emails and electronic communications sent by or to us.
We follow strict security procedures in the storage and disclosure of information that you have given us to prevent unauthorised access.
What types of personal information we process
We may process the following types of personal information:
- contact details including email details, addresses and phone numbers;
- age or date of birth;
- bank account balances, financial statements, credit reporting information and employment details;
- trading knowledge and experience;
- user names and passwords;
- information relating to your account including your account history, activity and orders;
- IP address;
- social security number, national insurance number, passport or other MiFIR national identifier;
- transaction reporting reference;
- power of attorney / agent details;
- phone device type;
- operating system;
- device ID;
- cookie ID;
- Google 360 ID;
- GUID; and
- information about your use of our services, products and facilities (including information gained when you use our learning tools, demo accounts and trading simulators).
How we check your identity
To comply with applicable regulations we need to confirm the name and address of our customers and certain third parties. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit.
Using your personal information
As well as checking your identity, the personal information we hold may be used for:
- considering any of your applications;
- carrying out risk assessments;
- complying with our legal and regulatory obligations;
- performing our obligations under any contract we have with you;
- administering our relationship with you including resolving queries or issues;
- establishing and managing your account;
- reviewing your ongoing needs;
- providing you with the information, products and services that you request from us;
- checking your instructions to us;
- investigating any complaint you may make;
- providing evidence in any dispute or anticipated dispute between you and us;
- recovering amounts payable;
- training our staff;
- enhancing our customer service and products;
- undertaking product development and analysis; and
- detecting or preventing fraud or other crimes.
Where you have consented to direct marketing, we may send you marketing material from time to time by post, email, telephone, SMS or other electronic messaging services.
We also use technology to make decisions automatically or to build profiles about you. This technology uses logic that assesses whether our products are suitable for a potential customer, which helps us to determine whether or not it is appropriate for a potential customer to open an account with us. This means that you may not be able to open an account with us if our technology determines that it would not be appropriate for you to do so based on your financial knowledge and trading experience. If you ever think our machines have got it wrong, you can ask for a human to look into it. (See “Your Rights - Rights in relation to automated decision making and profiling”.)
When we may share your information
We may share your personal information with:
- any regulatory, law enforcement or tax authority;
- such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police;
- our associated companies;
- third-party service providers and advisers who provide us with administrative, financial, research or other services in connection with the services we provide to you;
- our introducing brokers and other commercial partners;
- our professional advisers;
- credit reference agencies;
- our auditors for the purposes of carrying out financial and regulatory audits;
- our agents, including credit reference agencies, acting on our behalf, carrying out such credit and identity checks, including money laundering checks, compliance regulatory reporting and fraud prevention checks, as we may reasonably consider necessary or desirable, including requesting a reference from your bank or any credit reference agency. Any third party referred to in this clause may share any personal information concerning you with us and other organisations involved in credit reference, the prevention of fraud and/or crime and/or money laundering or for similar purposes or to recover debts involved;
- courts, tribunals, regulatory or tax authorities and government agencies to enable us to enforce our agreement with you or to comply with the requirements of a court, regulator, tax authority or government agency;
- the purchaser or potential purchaser of one or more of our businesses or product/service lines and their professional advisers; and
- our trade repository.
Please also note that disclosure to the trade repository or regulators may also result in certain anonymous transaction and pricing data becoming available to the public.
Generally, we require that organisations outside our associated companies with whom we share your personal information acknowledge the confidentiality of your data and undertake to respect your right to privacy.
Information, which we obtain indirectly
In some cases, we are also provided with your name and contact details by our third party referrers.
We also gather information relating to you and your online behaviour:
- to help optimise our website, to give you a good user experience and to personalise your use and our communications to you;
- to help us monitor, support and improve the performance of our site (by analysing your use and experience of our site);
- to help us understand more about you and the products and services you use and are interested in; and
- to tailor the online advertising you receive.
Knowing more about you helps us to understand our customers better, and means we can give you recommendations about products and services you may be interested in, and provide you with relevant advertising and customised communications that are of interest to you.
We combine information that you provide to us with information that is publicly available and/or that we receive from third parties such as advertisers and/or other reputable sources who have obtained your permission to do so, or have otherwise explained to you that this may happen.