Wire uses Zendesk for customer inquiries and may store supplied personal data while the support case is resolved. It cites a legitimate interest in customer support under Article 31(1) and (2) FADP or Article 6(1)(f) GDPR. It says the personal data processed for the support inquiry is deleted once the inquiry has been completed.
Supporting quotations
If you contact Wire customer service, the personal data you provide may be stored for the duration of the support case resolution. Wire uses Zendesk to process customer enquiries. The legal basis for the processing of your data for processing the support request is a legitimate interest (Art. 31 sec. 1, sec. 2 FADP or Art. 6sec. 1 lit. f GDPR). Our legitimate interest is to provide a support service for our customers. We delete your personal data processed for the processing of the support enquiry after the processing of your enquiry has been completed.
Sharing & Disclosure · Company practice
Consent permits affiliate sharing or longer retention of suitable applications
With consent, Wire says it will pass application data to affiliates or retain it longer when it considers an application suitable but cannot offer a position. It cites Article 31(1) FADP or Article 6(1)(a) GDPR. Consent can be revoked at any time with future effect.
Supporting quotations
With your consent, we will also pass on your application data to affiliated companies or store your application data for a longer period if we consider your application suitable but are unable to offer you a position. The legal basis for data processing is Art. 31 sec. 1 FADP or Art. 6 sec. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future.
Cross-references
contrast (model-proposed): The application-deletion exception is worded ambiguously — contrast: Longer application retention is consent-based in one paragraph, while the deletion exception says consent has not been given. The analysis reports this textual tension without reversing the wording.
Sharing & Disclosure · Company practice
Wire’s LinkedIn presence uses links or plugins without a page-load connection
Wire maintains a LinkedIn fan page to communicate with customers and describe services, naming LinkedIn Ireland Unlimited Company as provider. It says only simple links or plugins that do not connect on page loading are used. That does not mean a visit to the LinkedIn fan page avoids tracking: the following paragraph says LinkedIn may collect technical and cookie data, track network or plugin-site activity, and personalize content or advertising, outside Wire’s influence.
Supporting quotations
We maintain a presence (a so-called "Fan Page") on the social media network LinkedIn, which is offered by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"), to communicate with customers and inform them about services. Only simple links or plugins that do not connect to social networks upon page loading are used.
We use the technical platform and services of LinkedIn to operate the respective Fan Page. We would like to point out that you use our Fan Page and its functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). When you visit our Fan Page, LinkedIn may collect certain technical data (including the IP address of your end device) and other information that is stored on your end device in the form of Cookies. We have no influence on and no details about the processing of your data by LinkedIn. Data processing may differ depending on whether you are registered and logged in to the LinkedIn network or whether you visit the page as a non-registered and/or non-logged-in user. LinkedIn may track your movement on the LinkedIn network or visits on websites with integrated LinkedIn plugins. LinkedIn may assign the collected information to your user profile. This data can be used to personalize content or advertising to you. If you wish to avoid this, you should log out or deactivate the “stay logged in” function, delete the cookies on your device and restart your browser. Please also note that the data collected about you in this context may be transferred to countries outside the European Economic Area (EEA), in particular the USA, by the respective provider of the social network and processed there. Further information on the data processing by LinkedIn are available in their privacy policy at [https://www.linkedin.com/legal/privacy-policy](https://www.linkedin.com/legal/privacy-policy).
Not stated here
LinkedIn’s linked privacy policy is not supplied; its further processing terms cannot be explained here.
Sharing & Disclosure · Company practice
HubSpot receives device and form data, with possible US transfers
Website visits or use of HubSpot services transmit technical data, including IP address, operating system, browser and language, and supplied inputs such as cookie settings and form entries to HubSpot. Wire uses European server locations, so data generally stays within the EU or EEA, but allows individual US transfers. The policy says these rely on Article 45 GDPR because HubSpot is certified under the EU–US Data Privacy Framework. Wire says a data-processing agreement makes HubSpot act on its instructions and behalf under Article 28 GDPR; CRM data is used only for technical inquiry processing and not passed to third parties.
Supporting quotations
When you visit our Website or when you use a service provided by HubSpot (e.g., the HubSpot Cookie Banner or form), certain technical data about your end device (IP address, information about the operating system and browser used, browser language, etc.) and any information entered by you in the respective tool (e.g., cookie settings, entries in the respective forms) are transmitted to Hubspot's servers. We use European server locations (i.e. servers of our partner HubSpot Ireland), so that the data is generally not transmitted to server locations in third countries outside the EU or the EEA. If Hubspot transfers data to the USA in individual cases, this data transfer takes place on the basis of Art. 45 GDPR, as Hubspot is certified according to the so-called EU-US Data Privacy Framework and is therefore subject to an adequacy decision of the EU Commission.
We have concluded a data processing agreement with Hubspot. Hubspot only processes the data in accordance with our instructions and on our behalf. The transfer of data to Hubspot is therefore based on Art. 28 GDPR. Hubspot only uses the data received as part of the CRM system for the technical processing of inquiries and does not pass it on to third parties.
Google may transfer service data outside the EU, including to the US
For the described Google functions, data may be sent to servers outside the EU, particularly Google LLC in the US, where necessary to provide the services. Wire says Google LLC is certified and listed under the EU–US Data Privacy Framework and relies on the EU adequacy decision and Article 45(1), first sentence, GDPR for US transfers. The policy presents this as an adequate and consistently high level of protection; this card reports that claim rather than independently verifying certification or protection.
Supporting quotations
In connection with the above-mentioned functions, Google may also transfer the data processed in this context to servers outside the EU, in particular to Google LLC in the USA, insofar as this is necessary for the provision of these services. For the USA, the EU-U.S. Data Privacy Framework is an adequacy decision by the EU Commission that certifies certified companies as having an adequate level of data protection within the meaning of the GDPR. Google LLC is certified under the EU-U.S. Data Privacy Framework and is also included in the list maintained by the U.S. Department of Commerce (Data Privacy Framework List). When data is transferred to Google LLC servers in the USA, a consistently high level of data protection is therefore guaranteed. Insofar as data is transferred to the USA, such a third-country transfer is based on Art. 45 (1) sentence 1 GDPR.
Countly reports stay on separate EU servers and are not linked to Wire accounts
Wire says it does not use Countly information to identify users and cannot link it to Wire accounts because its self-hosted analytics server is separate from account and Messenger servers. It does not store Countly IP addresses or share the information with Countly Ltd or other third parties. It says the data stays within the EU or EEA and is used only for anonymous statistics and reports on Messenger stability, functionality and usage. This assurance concerns Countly, not all technical data Wire handles.
Supporting quotations
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.
Sharing & Disclosure · Company practice
Wire uses affiliates and lists providers for business-related processing
Wire uses affiliates, particularly Wire Germany GmbH, to provide its services. Its provider table specifically concerns business prospects and business-account users. It lists AWS for hosting in the EU; ‘Google Workplace’ for email in the EU; Box for signature management in the EU; Zendesk for customer support in the EU; Stripe for payment services in the USA; Contract Hero for contract management in the EU; and Salesforce for CRM services in Germany. These are the table’s stated functions and server locations, not a claim that every personal user sends data to every listed provider.
Supporting quotations
To provide Wire services, Wire uses the services of its affiliate companies, in particular Wire Germany GmbH, a limited liability company located in Germany.
For processing data of business prospects and business account users, Wire uses the following third parties:
Subprocessor Function Server location
Amazon Web Services (AWS) Hosting EU
Google Workplace E-mail Provider EU
Box Signature Management EU
Zendesk
Customer Support EU
Stripe Payment Services USA
Contract Hero Contract Management EU
Salesforce CRM-Services Germany
Sharing & Disclosure · Company practice
The table’s EU analytics locations do not rule out the described US transfers
For business prospects and business-account users, the table lists Google Analytics for marketing in the EU and HubSpot for website hosting, marketing and CRM in the EU. Those server-location labels are qualified by the detailed sections: HubSpot generally uses European servers but may transfer data to the US in individual cases, and Google may send data outside the EU, especially to Google LLC in the US where necessary for the services. The notice cites Data Privacy Framework adequacy for those US transfers.
Supporting quotations
For processing data of business prospects and business account users, Wire uses the following third parties:
Google Analytics Marketing Activities EU
HubSpot Website Hosting & Marketing Activities, CRM Services EU
When you visit our Website or when you use a service provided by HubSpot (e.g., the HubSpot Cookie Banner or form), certain technical data about your end device (IP address, information about the operating system and browser used, browser language, etc.) and any information entered by you in the respective tool (e.g., cookie settings, entries in the respective forms) are transmitted to Hubspot's servers. We use European server locations (i.e. servers of our partner HubSpot Ireland), so that the data is generally not transmitted to server locations in third countries outside the EU or the EEA. If Hubspot transfers data to the USA in individual cases, this data transfer takes place on the basis of Art. 45 GDPR, as Hubspot is certified according to the so-called EU-US Data Privacy Framework and is therefore subject to an adequacy decision of the EU Commission.
In connection with the above-mentioned functions, Google may also transfer the data processed in this context to servers outside the EU, in particular to Google LLC in the USA, insofar as this is necessary for the provision of these services. For the USA, the EU-U.S. Data Privacy Framework is an adequacy decision by the EU Commission that certifies certified companies as having an adequate level of data protection within the meaning of the GDPR. Google LLC is certified under the EU-U.S. Data Privacy Framework and is also included in the list maintained by the U.S. Department of Commerce (Data Privacy Framework List). When data is transferred to Google LLC servers in the USA, a consistently high level of data protection is therefore guaranteed. Insofar as data is transferred to the USA, such a third-country transfer is based on Art. 45 (1) sentence 1 GDPR.
Sharing & Disclosure · Restriction or exception
Countly is listed as a tool, but Wire says it receives no analytics data
The business-processing table lists Countly for product analytics with server location Germany. The detailed Messenger section says Countly is self-hosted by Wire on EU servers, separate from accounts and Messenger, with no information shared with Countly Ltd or another third party and no transfer outside the EU or EEA. The table therefore should not by itself be read as saying the Countly provider receives user analytics.
Supporting quotations
For processing data of business prospects and business account users, Wire uses the following third parties:
Countly Product Analytics Germany
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.
Third-party disclosures are limited to service, legal and rights-related grounds
Wire says it shares personal data only to the extent needed for the third party’s service, when legally required, or when necessary to enforce its terms or protect its rights. It says disclosure to public authorities occurs only where Swiss law requires it. The following provision additionally permits disclosures for acquisitions or similar financial transactions to the extent data-protection law permits, so the general service/legal/rights list is not the whole disclosure rule.
Supporting quotations
Wire only shares personal data with third parties if and to the extent necessary to provide the third party's service (e.g., to respond to a support request), if legally required, or if it is necessary to enforce the terms of service and/or protect Wire's rights. Wire will not disclose your data to public authorities unless Wire is required to do so under Swiss law.
Additionally, to the extent permitted by data protection law, Wire may disclose your personal data to third parties if we (or our affiliates) are acquired by or involved in a transaction with similar financial implications. In such cases, we will make reasonable efforts to ensure the third party processes your data in accordance with this privacy policy. If your personal data is subsequently used in a manner different from what is described in this policy, we will ask the third party to notify you in advance.
Sharing & Disclosure · Company practice
An acquisition may involve disclosure, with limited assurances about later use
To the extent data-protection law permits, Wire may disclose personal data if Wire or an affiliate is acquired or involved in a transaction with similar financial implications. Wire promises reasonable efforts to have the third party follow this policy. If later use differs, Wire says it will ask the third party to notify users in advance; it does not itself promise to deliver that notice or guarantee unchanged use.
Supporting quotations
Additionally, to the extent permitted by data protection law, Wire may disclose your personal data to third parties if we (or our affiliates) are acquired by or involved in a transaction with similar financial implications. In such cases, we will make reasonable efforts to ensure the third party processes your data in accordance with this privacy policy. If your personal data is subsequently used in a manner different from what is described in this policy, we will ask the third party to notify you in advance.
Transfers outside Switzerland rely on adequacy, clauses or another safeguard or exception
For third parties outside Switzerland, Wire says it ensures one or more of: a country recognized as adequate by both Switzerland and the European Commission; Standard Contractual Clauses with the recipient; or another safeguard or exception under FADP and GDPR. When users share data through third-party services within the app, such as YouTube, Spotify or Giphy, that shared data is subject to those services’ privacy policies.
Supporting quotations
If Wire transfers personal data to third parties located outside Switzerland (see the list of third parties above), Wire ensures that (i) the third party is located in a country recognized by Switzerland and the European Commission as providing an adequate level of data protection, and/or (ii) Wire has entered into "Standard Contractual Clauses" with the third party and/or (iii) another safeguard or an exception under FADP and GDPR applies. If you use third-party services like YouTube, Spotify, Giphy, etc., via the Wire application, any data you share with these services is subject to their privacy policies.
Not stated here
Those third-party privacy policies and any specific contractual clauses are not supplied; their detailed terms are not established here.
Wire says it does not rent or sell your data or use it for targeted advertising or other profiling. Later, however, it describes consent-based HubSpot analysis of website and newsletter behavior, linking analytics to form inputs, determining services of interest and contacting people for advertising. These are provisions in tension; the policy does not explain exactly how its broad no-profiling statement fits those marketing practices. Separately, LinkedIn may profile fan-page visitors for personalized content or ads outside Wire’s influence. The broad statement should not be read as a promise that all services are free of tracking or marketing.
Supporting quotations
Wire does not rent or sell your data to third parties. Your data is also not used for targeted advertising or other forms of profiling. Unless the context requires otherwise, any reference to "you", "your", or "yourself" in this privacy policy includes the respective organization using the team management functionality of the apps, website, and/or service, the respective team admin, and the respective team member (as defined in our terms of service).
We use the technical platform and services of LinkedIn to operate the respective Fan Page. We would like to point out that you use our Fan Page and its functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). When you visit our Fan Page, LinkedIn may collect certain technical data (including the IP address of your end device) and other information that is stored on your end device in the form of Cookies. We have no influence on and no details about the processing of your data by LinkedIn. Data processing may differ depending on whether you are registered and logged in to the LinkedIn network or whether you visit the page as a non-registered and/or non-logged-in user. LinkedIn may track your movement on the LinkedIn network or visits on websites with integrated LinkedIn plugins. LinkedIn may assign the collected information to your user profile. This data can be used to personalize content or advertising to you. If you wish to avoid this, you should log out or deactivate the “stay logged in” function, delete the cookies on your device and restart your browser. Please also note that the data collected about you in this context may be transferred to countries outside the European Economic Area (EEA), in particular the USA, by the respective provider of the social network and processed there. Further information on the data processing by LinkedIn are available in their privacy policy at [https://www.linkedin.com/legal/privacy-policy](https://www.linkedin.com/legal/privacy-policy).
With your consent, HubSpot also uses Cookies to analyze your use of the Website and the use of the newsletter for statistical and marketing purposes. The statistical analyses and evaluations of logged user behavior help us to optimize our Website and further develop it based on user needs. We also use information to determine which of our company's services are of interest to customers and newsletter subscribers and to contact them for advertising purposes.
The HubSpot Cookies are stored for a maximum period of 12 months and then automatically deleted. If this analytics feature is activated, the data collected with HubSpot (including technical information such as IP address, URL and language of the browser, approximate location, duration of a visit, privacy settings, interactions on the Website) can be linked to the information you provide to us in the forms and evaluated together. We receive the raw data collected and the statistical reports from HubSpot.
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.
Not stated here
LinkedIn’s linked privacy policy is not supplied here; this card cannot explain its additional terms.
The policy does not expressly reconcile the broad no-profiling statement with its later consent-based marketing and behavior-linking practices.
Cross-references
contrast (model-proposed): Consent-based HubSpot analytics can connect behavior with form information — contrast: The broad statement against targeted advertising or profiling sits alongside consent-based behavior linking and interest-based advertising contact. Both are preserved without deciding the unstated reconciliation.