Messenger collects additional technical data to move data between devices
Wire collects technical information such as device types to facilitate transfers between devices. It says the service is designed to minimize technical data collection needed for operation. It cites consent and contract performance, naming Article 31(1) FADP and Article 6(1)(a) and (b) GDPR. Additional detail is referred to separate Privacy and Security Whitepapers.
Supporting quotations
Wire collects and processes additional technical data, such as device types, as part of the provision of the Wire Messenger to facilitate the transfer of data between devices. The service is designed to minimize the collection of technical data necessary for service operation. The legal basis for this processing is user consent and contract performance (Art. 31 sec. 1 FADP or Art. 6 sec. 1 lit. a, lit. b GDPR). Further information on additional data can be found in the [Privacy Whitepaper](https://wire-docs.wire.com/download/Wire+Privacy+Whitepaper.pdf) and [Security Whitepaper](https://wire-docs.wire.com/download/Wire+Security+Whitepaper.pdf).
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The linked Privacy and Security Whitepapers are not supplied; additional data categories or technical details in them cannot be determined here.
Data Access & Collection · Company practice
Cookies may be set by Wire or integrated third parties
Some Wire services use cookies and similar technologies stored by a browser or app. They may contain visit duration or user inputs and may be set by Wire or integrated third parties. The general description gives lifetimes from a session to a maximum of two years; particular functions and lifetimes are described in the relevant banner and service or tool sections.
Supporting quotations
Certain Wire Services use cookies and similar technologies (hereinafter collectively referred to as "Cookies"). Cookies are small text files that are stored on your device by your browser or app. They contain various information, e.g. duration of the website visit or user input. They may be set by Wire as the provider of the Website (so-called first-party cookies) or by third parties whose services are integrated in the Wire Services (so-called third-party cookies). Cookies can be stored for different lengths of time (e.g. duration of page use, several weeks up to a maximum of two years).
Further details on the functions and storage periods of the Cookies used by Wire can be found in the relevant cookie banner and in the following sections of this privacy policy (in each case for the relevant Wire Service and tool that uses the Cookies).
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The live cookie banner is not supplied, so this card cannot enumerate settings beyond those in the policy.
Data Access & Collection · Company practice
Browsing the website sends technical information even without an account
For information-only visits without registration, login or communication, the browser automatically sends data that Wire temporarily logs. It lists IP address; access date, time and GMT offset; requested page; transferred data volume; browser type, settings, language and version; operating system; last page visited; and access or HTTP status. The purpose is website delivery, stability and security. Wire cites Article 6(1)(f) GDPR legitimate interests in safe operation, network security, optimization and protection against attacks and disruption.
Supporting quotations
As part of a visit of the Wire Website for information purposes only (i.e. use without registration, login or communication with the provider via the website), information is automatically sent to the provider's server by the user's browser and temporarily stored there in a so-called log file. In this context, Wire collects and processes the following information and personal data in particular:
IP address
Date and time of accessing the Website
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Amount of data transferred
Browser type and browser settings
Language and version of the browser software
Operating system used
Last page visited by the user
Access status/HTTP status code.
This information is technically necessary for Wire to deliver the Website and to ensure its stability and security. The personal data collected when the website is accessed, in particular the user's IP address, will be deleted no later than thirty (30) days after collection, unless an attack or threat by the user has been recognized.
Insofar as Wire collects and processes the user's personal data, in particular the user's IP address, when the Wire Website is accessed and visited, the legal basis for this is Art. 6 sec. 1 lit. f GDPR. Wire has a legitimate interest in providing the Website in a stable, secure, and safe manner. In particular, Wire intends to ensure a level of protection appropriate to the risk for the personal data it processes, to ensure network and information security and to optimize the Wire Website and protect it from attacks, disruptions and damage.
Data Access & Collection · Company practice
Google Analytics sends website interaction and device data to Google
Wire uses Google Analytics from Google Ireland and Google Inc. to analyze website interactions and improve its offering through reports. With consent, cookies send Google page views, behavior such as clicks, duration and scroll depth, approximate location, IP address, browser and internet-provider details, device and screen information, referral source and a random user ID. IP anonymization normally truncates the address in the EU or EEA; exceptionally the full address reaches a US server before truncation. Consent covers collection, further processing and device cookies, and can be withdrawn without changing the lawfulness of earlier processing.
Supporting quotations
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and Google Inc. Mountain View, USA (‘Google’). The purpose of our use of Google Analytics is to analyse your user interactions on our website and to improve our offering and make it more interesting for you as a user based on the statistics and reports obtained.
Google Analytics uses cookies to enable an analysis of your use of the website. During your visit to our website, the following data, among other things, is transmitted to Google and, if necessary, also to Google servers in the USA: pages accessed, your behaviour on the pages (e.g. length of stay, clicks, scroll depth), your approximate location (country and city), your IP address, technical information such as browser, internet provider, device and screen resolution, the source of your visit (i.e. which website or advertising medium brought you to us) and a randomly generated user ID. However, due to IP anonymisation on this website, your IP address will be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The data collected by Google Analytics is stored for a maximum of 14 months. The storage period for the cookies used by Google can be found in the cookie banner. An overview of the cookies used by Google can be found at https://policies.google.com/technologies/cookies?hl=de. The legal basis for the collection and further processing of information is your consent in accordance with Art. 31(1) DSG or Art. 6(1)(a) GDPR.
The legal basis for the use of cookies or similar technologies on your device is also your consent. You may revoke your consent at any time without affecting the lawfulness of processing prior to revocation.
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The linked Google cookie overview and the cookie banner are not supplied; their additional settings and cookie-specific periods are not known here.
Data Access & Collection · Company practice
App stores independently collect download data
The store distributing the app, such as Apple’s App Store or Google Play, collects data needed for downloading. This may include name, email, postal code, download time, IP address, device identifier or IMEI, crash logs and, where applicable, payment information. Wire says this collection is basically carried out by the store without Wire’s participation or influence. Wire processes store-provided data only as necessary to supply the app, and any installation processing by Wire relies on the download/use contract under Article 6(1)(b) GDPR.
Supporting quotations
When downloading the App, the operator of the app shop through which the App is made available (for example Apple, Inc. for the App Store and Google LLC for the Google Play Store) collects personal data required for the download. This data may include your name, your email address and your postal code, time of download, the IP address, and the individual device identification number of your end device (so-called IMEI), crash-logs as well as your payment information, if applicable. This collection and processing of your personal data is, however, basically carried out solely by the respective app shop operator, without participation or influence by Wire. Further details on this data processing are available in the privacy policy of the relevant app shop operator.
We process the personal data provided by the app store operator only to the extent necessary for the provision of the App. If we process personal data in the course of installation, this is done on the basis of the contract for the download and use of the Wire App that you have concluded, in accordance with Art. 6 sect. 1 lit. b GDPR.
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The relevant app-store privacy policies are not supplied; their additional processing rules are not described here.
Data Access & Collection · Company practice
Countly analytics is optional and uses a pseudonymous ID
With consent, Wire uses Countly in Wire cloud to analyze crashes and events such as app opening, closing or feature use, to fix errors and improve Messenger stability and features. When activated, Countly gathers these usage events and technical information such as IP address, app version, device type and operating system under a generated pseudonymous ID, and sends it to Wire’s self-hosted EU servers. Wire says it does not store the collected IP addresses. Consent is obtained through the Messenger banner under Article 31(1) FADP or Article 6(1)(a) GDPR and may be withdrawn there at any time for the future.
Supporting quotations
With your consent, we use the analytics tool "Countly" in Wire cloud to help us fix errors and further optimize the Wire Messenger based on user needs. Countly collects and analyses crash reports and information on certain other events, such as when a particular feature is activated. This gives us statistical information that helps us improve the stability and features of the Messenger.
When Countly is activated, certain information about your use of the Messenger, such as whether and when an error occurs or a certain event occurs (e.g., opening or closing of the App, using of a particular feature), and other technical information (e.g., IP address, app version, device type, operating system) is collected using a pseudonymous ID generated by Countly. The information is transmitted to our (self-hosted) EU servers. Any ID and information stored by Countly are automatically deleted from your device no later than 365.
We do not use the information transmitted by Countly to identify you. We cannot link this information to your Wire account, since it is only sent to a (self-hosted) server which is separated from the Wire servers hosting the Wire user accounts or the Messenger. We also do not store any IP addresses collected by Countly. We do not share the information with third parties. Countly is self-hosted by Wire on EU servers, so no data collected or analyzed by Countly is shared with the tool provider (Countly Ltd, with its principal place of business located at 9th Floor 107 Cheapside London United Kingdom EC2V 6DN) or any other third party. The data is not transferred to countries outside of the EU or EEA. We only use the collected information to create anonymous statistics and reports about the stability, functionality, and usage patterns related to the Messenger.
We only use Countly in the Messenger with your consent which is obtained through a consent banner integrated in our Messenger. Therefore, the legal basis for the data processing as described above is user consent (Art. 31 sec. 1 FADP or Art. 6 sec. 1 lit. a GDPR). You can withdraw your consent at any time with effect for the future. Please make the appropriate settings via our consent banner.
Data Access & Collection · User right or choice
Providing data is not obligatory, but services generally need technical data
Wire says users are not contractually or legally obliged to provide personal data on its website, fan pages or other services. However, the services generally cannot be used without certain technical information, such as IP addresses and other logs. The absence of an obligation to provide data therefore does not promise access without the data necessary to operate the service.
Supporting quotations
You are not contractually or legally obliged to provide personal data on the Website, Fan Pages, or other Wire Services. However, without the provision of certain technical data (e.g. the IP address and other log data), Wire Services can generally not be used.
Account registration collects profile details that may be shown to other users
The general account paragraph requires a user name, display name and email; team accounts may require billing data. Profile data supports the service and may appear to users who search for or connect with you. It says this personal data is stored for the account’s duration. The Messenger-specific paragraph lists username, email and password as required and says additional profile information is optional. Both passages cite contract performance under Article 31(2)(a) FADP or Article 6(1)(b) GDPR; the notice does not fully reconcile the different lists of required details.
Supporting quotations
When users create a Wire account, they are required to provide a user name, a display name, and an email address. If a Team-Admin or Team-Member account is created, additional billing information might be required. This profile data is used to provide and support the service and can be displayed to other Wire users who search for or connect with them. Personal data is stored only for the duration of the account. The legal basis for this is contract performance according to Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR. Wire collects and processes the personal data that users voluntarily provide when registering for a Wire Service. This data is processed for the purpose of operating the relevant Wire Service and providing it to the user.
Users are only required to provide a username, email, and password to register for the Wire Messenger. Adding further information to a user profile is optional. Wire uses the so-called double opt-in procedure as part of the registration process to verify the provided email address. This means that after a user has registered for the Wire Messenger, an email with a verification code is sent to the user to confirm ownership of the email address. If an email address is not verified, the provided data will be deleted after one month. In addition to the information provided by the user in the registration form, Wire may also store the date and time of registration and verification, and the IP address of the device used in the registration process. This data is necessary to prove that the relevant account has been registered by a certain user or to trace the (possible) misuse of a user’s email address later.
The processing is necessary for the provision of the Wire Services to the user and, thus, based on Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (contract performance).
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The general account and Messenger-specific required-field lists differ; the notice does not resolve whether a separate display name is mandatory for Messenger.