Inquiry data is used to respond and deleted when no longer needed for the inquiry
Wire processes information supplied through email or web forms, including names, contact details, company affiliation, role and other information, to answer requests. Requests preparing a contract with the user rely on Article 31(2)(a) FADP or Article 6(1)(b) GDPR; other requests rely on Article 6(1)(f) GDPR legitimate interests in responding. It says data is deleted once the inquiry is fully processed and further communication is unnecessary.
Supporting quotations
When users submit inquiries (e.g., via email or a web form), the data they provide, such as their name, email address, telephone number, affiliation with a company, role in the company or other information, is processed to respond to their request. The legal basis is Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (pre-contractual measures), insofar as the request serves to prepare a contract with the user. Otherwise, the legal basis is Art. 6 sec. 1 lit. f GDPR (legitimate interest), in which case Wire’s legitimate interest is to appropriately respond to the user’s request. Data is deleted once the inquiry is fully processed and further communication is unnecessary.
Use & Processing · Company practice
Newsletter subscriptions use consent and email verification
Subscribers’ names and email addresses are used to send the newsletter; its content is described in the subscription form or consent declaration. An emailed verification code confirms the subscription and email ownership. Unverified subscription data is deleted within one month. Wire may retain registration and verification timestamps and the registration IP address to prove registration or investigate email misuse. This processing relies on consent under Article 31(1) FADP or Article 6(1)(a) GDPR. Users can withdraw consent for the future at any time, for example via the unsubscribe link; the policy says user data is retained only while the subscription is active.
Supporting quotations
If users subscribe to Wire's newsletter, their email address and name are processed to send the newsletter. Users can subscribe to Wire's newsletter using the form on our Website. Details on the content of Wire’s newsletter are available in the declaration of consent or in the newsletter subscription form.
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 newsletter, an email with a verification code is sent to the user to confirm the subscription and ownership of the relevant email account. If the subscription is not verified, the provided data will be deleted after one month at the latest. 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 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). Users can unsubscribe at any time, i.e. users can freely withdraw their consent at any time and with effect for the future, for example by clicking on the unsubscribe link at the bottom of every newsletter email. User data is only retained while the subscription is active.
Not stated here
The subscription form and consent declaration are not supplied, so the particular newsletter content described there is unknown.
Use & Processing · Company practice
Usage statistics and crash data may include pseudonymized team IDs
Wire processes individual usage data to compile anonymous statistics and crash logs and may record pseudonymized Team IDs to monitor customer success and improve services. Where consent is not required, personal data processing relies on legitimate interests in smooth service provision, citing Article 31(2)(a) FADP or Article 6(1)(f) GDPR. Where consent is required, processing begins only after consent under Article 31(1) FADP or Article 6(1)(a) GDPR. Users can prevent this processing at any time, with instructions referred to an FAQ. The stated deletion limit is 365 days.
Supporting quotations
We process individual data about the use of the Wire Services in order to compile anonymous usage statistics and crash logs. Furthermore, we may record pseudonymized Team IDs to monitor customer success and enhance our services. Insofar as personal data is processed for this purpose and your consent is not required for processing, we process your data on the basis of a legitimate interest (Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. f GDPR). Our legitimate interest is the smooth provision of Wire Services. Insofar as personal data is processed for this purpose and your consent is required for processing, we will only process your data after you have given your consent (Art. 31 sec. 1 FADP or Art. 6 Sec. 1 lit a GDPR). You can prevent the processing of your data for these purposes at any time, see FAQ. This data will be deleted after 365 days latest.
Not stated here
The referenced FAQ is not supplied; this paragraph does not give the steps to prevent processing.
Use & Processing · Company practice
Application data supports recruitment, claim defense and possible employment
Wire processes applicant data to conduct recruitment, citing Article 31(2)(a) FADP and Article 6(1)(b) GDPR for contract preparation. It may also use it where necessary to defend claims arising during recruitment, invoking legitimate interests and citing Article 6(1)(f) GDPR alongside the source’s wording ‘Art. 31 sec. 2 lit. a GDPR’. If employment follows, existing applicant data may be used for that relationship under Article 31(2)(a) FADP or Article 6(1)(b) GDPR. These are applicant-data purposes, not general permission to use Messenger conversations.
Supporting quotations
Your data will be processed for the purpose of carrying out the application process. The legal basis for data processing is Art. 31 sec. 2 lit. a FADP and Art. 6 sec. 1 lit. b GDPR (preparation of a contract). In addition, your personal data may be processed if this is necessary for the defence of legal claims asserted against us during the application process. The legal basis for this is Art. 31 sec. 2 lit. a GDPR or Art. 6 sec. 1 lit. f GDPR. The legitimate interest in the processing also lies in the aforementioned purposes. If an employment relationship is established between you and us, we may process the personal data that we have already received from you for the purposes of the employment relationship in accordance with Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (performance of a contract).
Not stated here
The claim-defense passage labels its Article 31 citation GDPR; the policy does not clarify this citation and this card does not correct it or infer the law’s contents.
Use & Processing · Company practice
Necessary cookies need no consent; optional statistics or marketing cookies do
Wire distinguishes necessary cookies for basic functions and security from optional cookies for statistics or marketing. It says necessary cookies do not collect marketing information or track behavior and may be used without consent. Optional cookies may track interactions and behavior for analysis, website optimization or marketing; Wire says storage and access occur only with explicit, freely given consent. Consent may be withdrawn for the future at any time, for example through cookie-banner settings.
Supporting quotations
Technically necessary Cookies: These Cookies are technically absolutely necessary to use the basic functions and ensure security of Wire Services. They do not collect information for marketing purposes or track the user behavior. Wire is permitted to use necessary Cookies without consent of the user.
Optional Cookies for statistics or marketing purposes: These Cookies can, among other things, track the user’s interactions and behavior. These Cookies are used for analysis, for example to help optimize our Website, or marketing purposes. Wire uses such Cookies (i.e. their storage on your end device and access to these Cookies) only with the user’s explicit and free consent. Users can freely withdraw their consents at any time with effect for the future, e.g. in the relevant settings of the cookie banner.
Use & Processing · Company practice
Wire uses fan-page interactions and statistics to communicate and improve the page
Wire processes information supplied through fan-page interactions, such as questions, to respond and communicate news. LinkedIn also processes personal data to give Wire statistics that Wire says cannot identify individual users or support conclusions about them. Wire uses these reports to adapt and optimize the page, potentially for market research and advertising. For statistics, Wire and LinkedIn are joint controllers under Article 26 GDPR. Wire cites Article 6(1)(f) GDPR legitimate interests in operating the page, communicating and assessing interactions. A separate linked agreement sets out joint-controller obligations.
Supporting quotations
We operate our Fan Page to communicate with the users active there and to be able to provide the latest news. We process the data from your use of the Fan Page that you provide to us and that require interaction. For example, if you ask us a question via a Fan Page, we process your information in order to answer your query appropriately.
When you visit our Fan Pages, LinkedIn also process personal data to provide us with statistics and insights into the use of our Fan Pages. The statistics help us to adapt our Fan Pages according to user needs and thus to continuously optimize them, which can also be done for market research and advertising purposes. We only receive statistical reports that do not allow us to identify individual users of LinkedIn or draw conclusions about them. The processing of data for statistical purposes is carried out by us and LinkedIn under joint responsibility in accordance with Art. 26 GDPR. We have regulated the conditions and obligations as joint controllers with the providers in an agreement, which is available at [https://legal.linkedin.com/pages-joint-controller-addendum](https://legal.linkedin.com/pages-joint-controller-addendum).
The aforementioned data processing by us is based on our legitimate interests in the operation of a Fan Page on the LinkedIn network, in the communication and interaction with the LinkedIn users, and in the evaluation of user interactions to improve the Fan Page. The data processing is therefore based in each case on Art. 6 sec. 1 lit. f GDPR.
Not stated here
The linked joint-controller addendum is not supplied, so its allocation of obligations cannot be described here.
Use & Processing · Company practice
HubSpot supplies website hosting, cookie consent, forms and CRM
Wire uses HubSpot, Inc., with an Irish branch, for EU-server website hosting, a cookie banner that obtains and documents consent, contact forms, and CRM processing of visitor and customer requests. Wire cites Article 6(1)(f) GDPR legitimate interests in providing these functions and efficiently handling requests. The underlying inquiry purposes are separately described as contract preparation where relevant, otherwise legitimate interests in responding; inquiry data is deleted once the inquiry is fully handled and further communication is unnecessary.
Supporting quotations
We use tools and hosting services provided by HubSpot, Inc., Cambridge, Massachusetts, US ("HubSpot") with a branch in Ireland (HubSpot European Headquarters, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Ireland) to provide the Website and certain features. In particular:
We host the Website on EU servers operated by HubSpot to make it available on the internet;
We have integrated the HubSpot Cookie Banner on our Website to obtain and document visitors’ consent to the storage of Cookies on our Website;
We have integrated HubSpot Forms on our Website to provide a user-friendly way to contact us via we forms;
We use the HubSpot CRM tool to process requests by visitors, users, or customers properly and efficiently.
The above data processing is based on Art. 6 sec. 1 lit. f GDPR (legitimate interest). Our legitimate interests are to provide site visitors with our Website featuring a legally compliant and user-friendly cookie banner solution, easy to use contact forms, and to provide us with an efficient CRM system to properly process user requests.
When users submit inquiries (e.g., via email or a web form), the data they provide, such as their name, email address, telephone number, affiliation with a company, role in the company or other information, is processed to respond to their request. The legal basis is Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (pre-contractual measures), insofar as the request serves to prepare a contract with the user. Otherwise, the legal basis is Art. 6 sec. 1 lit. f GDPR (legitimate interest), in which case Wire’s legitimate interest is to appropriately respond to the user’s request. Data is deleted once the inquiry is fully processed and further communication is unnecessary.
Use & Processing · User right or choice
HubSpot analytics consent can be withdrawn through the website banner
For the HubSpot marketing-cookie or newsletter-evaluation functions, Wire cites consent under Article 31(1) FADP and Article 6(1)(a) GDPR. Consent may be freely withdrawn at any time with future effect, for example through the website cookie banner. This continuation concerns HubSpot analytics, not a requirement for every website operation.
Supporting quotations
The service is used on the basis of your consent in accordance with Art. 31 sec. 1 FADP and Art. 6 sec. 1 lit. a GDPR. You can freely withdraw your consent at any time with effect for the future, e.g. in the cookie banner on our Website.
We only use these functions of HubSpot and the corresponding Cookies if you have given us your consent to the use of marketing Cookies on the Website or to the evaluation of the use of our newsletter (see the section on newsletters above) and the associated data processing.
Use & Processing · User right or choice
You can request restricted processing in specified situations
Under Article 32 FADP and Article 18 GDPR, the notice says you may request restriction while contested accuracy is checked, where processing is unlawful but you prefer restricted use to erasure, or where Wire no longer needs the data but you need it to establish, exercise or defend legal claims. These conditions differ from a general objection to legitimate-interest processing.
Supporting quotations
Right to restriction of processing (Art. 32 FADP / Art. 18 GDPR): You have the right to request the restriction of the processing of your personal data if
You contest the accuracy of the data, for a period enabling us to verify the accuracy.
The processing is unlawful, but you request the restriction of use instead of erasure.
We no longer need the data, but you need it for the establishment, exercise or defense of legal claims.
Use & Processing · User right or choice
You can object to legitimate-interest processing, subject to overriding grounds
The policy cites Article 32 FADP and Article 21 GDPR for a right to object at any time to personal-data processing based on legitimate interests. Wire says it will stop unless it can demonstrate compelling legitimate grounds overriding your interests, rights and freedoms. This is not an unconditional right to stop every type of processing.
Supporting quotations
Right to object (Art. 32 FADP / Art. 21 GDPR): You have the right to object at any time to the processing of your personal data, which is based on a legitimate interest. In this case, we will cease processing unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
Use & Processing · User right or choice
Consent can be withdrawn for the future at any time
Under the rights described in Article 7(3) GDPR and Article 31 FADP, users can withdraw personal-data processing consent at any time. Withdrawal takes effect for the future and does not change the lawfulness of processing before withdrawal. This right concerns consent-based processing.
Supporting quotations
Right to withdraw consent (Art. 7 sec. 3 GDPR / Art. 31 FADP): You have the right to withdraw your consent to the processing of your personal data at any time. The revocation applies to the future and does not affect the legality of the processing up to the time of revocation.