Information on Airwallet’s processing of personal data
Effective from 1 January 2024
Airwallet ApS is a private company that offers payment solutions and other services to its customers.
As part of our business, we record and use information about you (personal data). We do this to offer you the best solutions, to fulfil our agreements with you, and to comply with various legal requirements.
As part of our activities, we also record and use information about you (personal data) when you interact with us as a person associated with one of our business customers. You may be an authorised signatory, beneficial owner, director, employee, or a third party associated with our business customer.
We take all relevant precautions to protect your personal data in accordance with applicable law.
This information on our processing of personal data describes how Airwallet protects your personal data and your statutory rights.
Why do we record and use your personal data?
We record and use information about you in order to offer you the best advice and solutions, to protect you against fraud, to fulfil our agreements with you, and to comply with the legal requirements imposed on us.
This means that we record and use personal data when:
You have entered into or are considering entering into an agreement with us regarding a service or product, cf. Article 6.1(b) of the General Data Protection Regulation
You have given us consent to use your personal data for a specific purpose, cf. Article 6.1(a) of the General Data Protection Regulation
We are legally obliged to do so, cf. Article 6.1(c) of the General Data Protection Regulation, for example pursuant to:
The Anti-Money Laundering Act
The Bookkeeping Act
The Payment Services Act
The Data Protection Act
It is necessary to pursue Airwallet’s legitimate interests, cf. Article 6.1(f) of the General Data Protection Regulation. This may for example be to prevent misuse or loss, to strengthen IT and payment security, and/or as part of direct marketing purposes. In this context, we only record and use your personal data if our interest clearly outweighs your interest in us not processing your personal data.
When it is necessary for Airwallet or the business customer you are associated with to pursue a legitimate interest, cf. Article 6.1(f) of the General Data Protection Regulation. This may be the case if we or the business customer have a business or commercial reason for using your personal data, such as administering the services and products that the business customer has requested, and providing you with the necessary access to digital services. We may also use your personal data if we need it to prevent misuse and loss, or to strengthen IT and payment security, and/or as part of direct marketing purposes. In this context, we only use your personal data if our interest clearly outweighs your interest in us not processing your personal data.
What personal data do we record and use?
We record and use different types of personal data depending on which services or products you have ordered or are interested in, including:
Basic personal data, e.g. your name, contact details, address, phone number, nationality and country of residence
Any information about your occupation
ID documentation, e.g. photocopies of passport, driving licence or birth certificate
Account numbers and parts of payment card numbers
How you use our apps, which mobile device you use, your operating system and your IP address
Information about the services and products we deliver to you, including how you use them and your preferences in this regard
Sensitive data
We only record sensitive data to the extent necessary to advise you or offer you a product or service.
We may also record other personal data if it is necessary to deliver certain products or services to you, or if it is required of us by law.
Why and how do we record and use your personal data?
We record and use personal data in connection with our delivery of our services and products, including:
Payment services
Associated features
Digital solutions
We also record and use the information in connection with other activities relating to specific services and products, including:
Customer service, advice and administration
Development and administration of our products, services and business, including for testing our systems
Marketing of our services and products
Determination of fees and prices for our services and products
Identification and approval of customers
Risk management
To protect you and Airwallet against fraud
To fulfil statutory requirements
We collect the information directly from you or by observing your actions, for example when:
You complete applications or other forms in connection with ordering services and products
You submit certain documents to us
You speak with us on the phone. When you call us, and when we call you at your request or as a follow-up to your enquiry, the conversation may be recorded and stored for documentation and security purposes. Before an employee answers the phone or before you enter a telephone queue, you will be informed if the conversation is being recorded. In a few cases, for example in the event of long waiting times, your call may be transferred to an employee where the conversation is not recorded after all, without you being notified.
You use our website, our mobile apps, products and services
You participate in customer surveys or campaigns that we have organised
You communicate with us via electronic media, including for example emails
How long do we store your personal data?
We store your data for as long as it is necessary for the purpose for which your data was recorded and is being used. We therefore always store your data for as long as we are delivering a service or product to you. When your business relationship with us has ended, we normally store your data for a further 7 years. This is primarily to fulfil our obligations under the Bookkeeping Act, the Anti-Money Laundering Act, and requirements from the Danish Financial Supervisory Authority. In certain cases, we store your data for longer. This applies for example if the limitation period is 10 years, in which case we may store the data for up to 10 years.
Third parties and your personal data
Third parties we share your personal data with
In certain cases, we share your personal data with third parties inside and outside Airwallet:
If you have asked us to transfer an amount to another recipient, we pass on the information about you that is necessary to identify you and fulfil the agreement.
The bank(s) where you as a private customer hold your recipient and/or sender account or associated payment card. We do this to verify that the payment card/account belongs to you and can be used for payments.
If you are a user at a laundromat with Airwallet, the laundromat owner/operator will be able to access personal information such as name, phone number and transaction history in order to maintain and administer the service provided.
We pass on information about you to public authorities where this is required of us under applicable law or as a result of court orders and requests from the police, the enforcement court or other authorities, including to the State Prosecutor for Serious Economic and International Crime (SØIK) in accordance with the Danish Anti-Money Laundering Act, to the tax authorities in accordance with the Tax Control Act, and to Danmarks Nationalbank in connection with statistical purposes and similar purposes.
We may pass on your data internally within the company and to external business partners if we have your consent or we have a statutory right to do so, for example upon presentation of court orders.
In connection with IT development, hosting and support, we transfer personal data to data processors, including data processors in third countries outside the EU and EEA. We ensure that your rights are protected and that the level of protection is maintained in connection with such data transfers, for example through the use of standard contracts approved by the European Commission or the Danish Data Protection Agency. You can obtain a copy of these standard contracts by contacting us.
Profiling and automated decisions
Profiling
Profiling is a type of automated processing of your personal data. We only use profiling and data modelling to prevent money laundering, detect fraud and the risk of fraud, and assess the likelihood of default occurring.
Automated decisions
With automated decisions, we use our systems to make decisions based on the information we hold about you. We use automated decisions for example to prevent fraud. Automated decisions enable us to ensure that our decisions are fast, fair, efficient and correct based on the information we have.
Your rights
Access to your personal data
You can obtain access to the personal data we have recorded and use, including where it comes from and what we use it for. You can find out how long we store your data and who receives information about you, to the extent that we pass on personal data in Denmark and abroad. Your right of access may however be restricted by law or be exempt from the right of access.
Manual processing
You can gain insight into how an automated decision was made and the effects of the decision, and you are entitled to manual processing of any automated assessment.
Right to object
In certain cases, you have the right to object to our processing of your personal data. This applies among other things when the processing takes place on the basis of our legitimate interest.
Objection to direct marketing
You have the right to object to our use of your personal data for direct marketing purposes, including profiling in connection with such a purpose.
Correction or deletion of Airwallet’s data
If our data is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or deleted subject to the limitations that follow from applicable law or rights to process data. These rights are referred to as the “right to rectification”, the “right to erasure” and the “right to be forgotten”.
Restricted use
If you believe that the data we have recorded about you is incorrect, or if you have objected to our use of the data, you can request that we restrict the use of the data to storage. Use is only restricted until the accuracy of the data can be confirmed, or until it can be verified whether our legitimate interests outweigh your interests.
If you are entitled to request that we delete the data we have recorded about you, you can instead request that we restrict the use of this data to storage. If we solely need to use the data we have recorded about you to assess a legal claim, you can also require that other use of the data be restricted to storage. However, we may be entitled to use the data for other purposes, including to assess a legal claim, or if you have given your consent to this.
Withdrawal of consent
You can withdraw consent at any time. Please note that if you withdraw consent, we may not be able to offer you certain services or products. Please also note that we will continue to use your personal data, for example to fulfil an agreement we have entered into with you, or if we have a statutory right to do so.
Data portability
If we use data based on your consent or an agreement, and the processing of the data is automated, you have the right to receive a copy of the data you have provided in an electronic machine-readable format.
Updates
We update this information on our processing of personal data on a regular basis. In the event of a change, the “effective from” date at the top of this document will be changed. Any changes to the information on our processing of personal data apply to you and your data immediately. If changes affect how your personal data is processed, we will take reasonable steps to inform you of the changes.
Contact details and complaints
You are always welcome to contact us if you have questions about your rights and how we record and use your personal data. You can contact our department responsible for data protection at kontakt@airwallet.net. If you are dissatisfied with how we record and use your personal data, you can contact us on +45 7870 9999.