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.
Inference & Profiling · Company practice
Newsletter pixels track opens and clicks to assess readers’ interests
Wire uses embedded tracking pixels to see whether and when a newsletter is opened and which links are accessed. It uses the results to infer recipients’ interests and improve newsletter content. The newsletter processing is consent-based; users may unsubscribe and withdraw consent with future effect at any time.
Supporting quotations
We evaluate the use of the newsletter emails (e.g., opening rate, clicks) to improve the newsletter content with the help of so-called tracking pixels. Using the embedded tracking pixel, we can recognize whether and when a newsletter email has been opened and which links in the email have been accessed. By analyzing this information, we can draw conclusions about the recipients' interest in our newsletter content and improve and develop the newsletter accordingly.
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.
Data Access & Collection · Company practice
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).
Not stated here
The linked Privacy and Security Whitepapers are not supplied; additional data categories or technical details in them cannot be determined here.
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.
Sharing & Disclosure · Company practice
Support requests are handled through Zendesk
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.
Security & Safeguards · Context
Job applications can be made online; unencrypted application email is insecure
Applicants may use the website’s application link. Wire warns that unencrypted email and attachments are not secure. The following paragraph says application data is used for the application process, may be used where necessary to defend claims, and may be used for employment purposes if an employment relationship is established; sending an application is therefore separate from Messenger account registration.
Supporting quotations
You can apply to us online via the link on our website. If you apply to us by e-mail, we would like to expressly point out that sending unencrypted e-mails or e-mail attachments is not secure.
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).
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.
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.
Retention & Deletion · Context
The application-deletion exception is worded ambiguously
Wire says applicant data is not used beyond the described purposes and states deletion no later than six months after recruitment ends, subject to exceptions. It gives defense evidence under the German General Equal Treatment Act as an example of another legitimate interest preventing deletion. But it also writes ‘or you have not given us your consent to longer storage’, while the preceding paragraph makes longer retention consent-based. These passages do not provide a clear six-month deletion guarantee when consent is absent; this card preserves their wording without treating the apparent mismatch as permission to retain data without consent.
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.
Your application data will not be processed beyond the use described above. Your personal data will be deleted no later than 6 months after the end of the application process, unless deletion conflicts with other legitimate interests on our part or you have not given us your consent to longer storage. Another legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).
Not stated here
The intended effect of ‘have not given’ in the deletion exception is unclear and is not silently corrected.
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).
Not stated here
The live cookie banner is not supplied, so this card cannot enumerate settings beyond those in the policy.
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.
Retention & Deletion · Company practice
Session and persistent cookies have different deletion rules
Session cookies use a session ID to associate browser requests and recognize a returning computer, and are automatically deleted after the session, such as on browser closure. Persistent cookies remain on the device until their particular expiry, from a few hours to two years, or until deletion at the user’s request. The relevant banner and tool sections contain more specific periods.
Supporting quotations
Session Cookies: These Cookies are automatically deleted after a session, e.g. when the browser is closed. They contain a so-called session ID. This allows various requests from a browser to be assigned to the shared session and a computer to be recognized when the user returns to the Wire Website.
Persistent Cookies: These Cookies remain stored on the user’s end device and are automatically deleted after a certain period (depending on the specific Cookie, from a few hours to two years) or at the user’s request.
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).
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.
Linking & Identification · Company practice
LinkedIn may profile fan-page visitors and transfer their data abroad
When you visit Wire’s LinkedIn fan page, LinkedIn may collect device and cookie data, including IP addresses, track activity on its network or sites with LinkedIn plugins, and associate information with a profile for personalized content or advertising. Processing may vary by login and registration status. Wire says it has no influence over or details of LinkedIn’s processing and flags possible transfers outside the EEA, particularly to the US. To avoid profile association, it suggests logging out or disabling persistent login, deleting cookies and restarting the browser; it does not promise these steps prevent all collection. It says use of interactive fan-page functions is the visitor’s responsibility.
Supporting quotations
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 additional processing terms are unknown here.
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.
Legal Rights & Agreement Rules · Procedure
Fan-page rights requests may go to Wire or LinkedIn
Data-subject rights requests can be sent to Wire or the social-network provider. If the recipient is not responsible or needs information from its partner, the request is forwarded to that partner. Questions about the network’s profiling and processing should go directly to the network; questions about your interactions with Wire should use Wire’s listed contacts.
Supporting quotations
To exercise your rights as a data subject, you can contact us or the provider of the respective social network. If one party is not responsible for responding or must receive the information from the other party, we or the provider will then forward your request to the respective partner. Please contact the respective provider of the social network directly if you have any questions about the profiling and processing of your data when using the Fan Page. If you have any questions about the processing of your interaction with us on our Fan Page, please write to the contact details provided by us above.
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.
Retention & Deletion · Company practice
Website-visit data has a 30-day deletion rule with a security exception
For website-access data, particularly IP addresses, Wire promises deletion within 30 days of collection unless it has recognized an attack or threat by the user. This is the specific website-visit rule; the exception does not state a separate retention deadline.
Supporting quotations
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.
Not stated here
This paragraph does not state how long website data is kept when an attack or threat is recognized.
Cross-references
qualifies (model-proposed): General logs have a 90-day limit; website visits have a specific rule — qualifies: Website visits have a specific 30-day deletion rule and security exception alongside the general 90-day log limit; the notice does not expressly reconcile the exception with that maximum.
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.
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.
Consent-based HubSpot analytics can connect behavior with form information
With consent, HubSpot cookies analyze website and newsletter use for statistics and marketing. Wire uses behavior reports to improve the website, determine services of interest to customers and subscribers, and contact them for advertising. When enabled, technical and interaction data—such as IP address, URL, browser language, approximate location, visit duration and privacy settings—can be linked with information supplied through forms. Wire receives both raw data and reports. HubSpot cookies expire within 12 months. Wire says these functions require consent to marketing cookies or newsletter-use evaluation and the associated processing, under Article 31(1) FADP and Article 6(1)(a) GDPR. Consent can be withdrawn at any time for the future, for example in the banner.
Supporting quotations
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.
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.
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.
Security & Safeguards · Company practice
Google Fonts are hosted locally rather than connecting directly to Google
Wire uses Google Fonts, provided by Google Ireland, but says the fonts are integrated locally on its own server, so this integration makes no direct connection to Google when the website is visited. To the extent data processing occurs, its purpose is uniform font and icon presentation, relying on the stated legitimate interest under Article 31(1) FADP and Article 6(1)(f) GDPR. This local-font statement does not describe Google Analytics.
Supporting quotations
Our Website uses Google Fonts for the integration of external fonts, a service provided by Google Ireland Ltd (Gordon House, Barrow Street, Dublin 4, Ireland; hereinafter referred to as ‘Google’).
The integration of Google Fonts takes place locally on our own server, so that no direct connection to Google's servers is established when you visit our Website.
Insofar as data processing is carried out, this is done for the purpose of the uniform presentation of fonts and icons. The legal basis is therefore our legitimate interest in the uniform presentation in accordance with Art. 31 sec. 1 FADP and Art. 6 sec. 1 lit. f GDPR.
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.
Not stated here
The linked Google cookie overview and the cookie banner are not supplied; their additional settings and cookie-specific periods are not known here.
Linking & Identification · Company practice
Google may link analytics data to a signed-in account and use it for its own purposes
The policy says Google also processes Analytics data under its own policy, potentially in usage profiles for product development and improvement, advertising effectiveness, market research, and personalized content and advertisements. If you are logged in to Google, data is directly associated with your account; Wire says to log out before activating Analytics if you do not want that association. Wire says it has no influence over Google’s further processing. Analytics itself requires consent, which may be revoked with future effect.
Supporting quotations
Google also processes the data collected via Google Analytics for its own purposes in accordance with its own privacy policy. The data may be stored by Google in usage profiles and processed, for example, for product improvement, the development of new products, measuring the effectiveness of certain advertising and market research, and the personalisation of content and advertisements. If you are logged in to Google, your data will be directly associated with your user account. If you do not want your data to be associated with your Google user account, you must log out before activating Google Analytics. We have no influence on the further processing of your data by Google. For more information, please refer to Google's privacy policy at https://policies.google.com/privacy.
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.
Not stated here
Google’s referenced privacy policy and linked cookie overview are not supplied; this card describes only what Wire’s notice says, not Google’s additional terms.
Retention & Deletion · Company practice
Google Analytics data is kept for at most 14 months
The policy states a maximum 14-month retention period for Google Analytics data. Cookie lifetimes are separately referred to the cookie banner and Google’s cookie overview; they should not be assumed to equal 14 months. The stated basis for collection and further processing is consent under ‘Art. 31(1) DSG’ or Article 6(1)(a) GDPR, and consent for device cookies may also be revoked without affecting earlier lawful processing.
Supporting quotations
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.
Not stated here
The linked cookie overview and banner are not supplied, so individual Google cookie lifetimes cannot be specified from them.
Sharing & Disclosure · Company practice
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.
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.
Not stated here
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.
Sharing & Disclosure · Company commitment
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.
Retention & Deletion · Context
Countly’s device-deletion sentence omits the time unit
The Countly paragraph says stored IDs and information are automatically deleted from the device ‘no later than 365’, without a unit. The general usage-data section separately gives a maximum of 365 days for usage statistics and crash-log data. That general rule supplies a stated usage-data limit, but it does not repair the incomplete device-specific sentence or establish that all Countly server and device records have identical lifetimes.
Supporting quotations
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 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 Countly device-deletion sentence does not supply a time unit; this card does not silently insert one.
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.
Retention & Deletion · Company practice
Where no period is specified, retention follows purpose and legal requirements
If this policy does not expressly state a retention period, Wire processes data only as long as needed for its purpose and deletes it immediately once that purpose ends. Legitimate reasons under applicable rules, including Article 17(3) GDPR and mandatory retention periods, may prevent deletion; data is then deleted immediately after the retention period expires. Consent-based data is deleted immediately on withdrawal unless statutory rules prevent deletion. The general purpose-based rule does not replace explicitly stated periods elsewhere.
Supporting quotations
Where we have not explicitly stated a retention period in this privacy policy, the following applies: We will only process your personal data for as long as is necessary to achieve the purpose of the processing. As soon as the purpose of the processing no longer applies, we will delete your data immediately, unless there are legitimate reasons within the meaning of the applicable legal regulations (e.g. Art. 17 sec. 3 GDPR), such as in particular legally prescribed retention periods, to prevent deletion. In this case, the data will be deleted immediately after the retention period has expired.
Data that we process on the basis of your consent will be deleted immediately after you withdraw your consent, unless statutory regulations prevent deletion.
Cross-references
qualifies (model-proposed): Consent can be withdrawn for the future at any time — qualifies: Consent withdrawal triggers immediate deletion in the retention section unless statutory rules prevent deletion; withdrawal does not retroactively invalidate earlier processing.
Legal Rights & Agreement Rules · User right or choice
Applicable law gives access and correction rights
Under applicable data-protection law, particularly FADP and GDPR, the policy says users may ask whether Wire processes their personal data and, if so, obtain that data and information including purposes, categories, recipients and planned retention. It cites Article 25 FADP and Article 15 GDPR. Incorrect or incomplete data may be corrected or completed immediately on request, citing Article 32 FADP and Article 16 GDPR. These are framed by the applicable law, not an assertion that every statute applies to every user.
Supporting quotations
Under the applicable data protection laws, in particular the Swiss Federal Act of Data Protection (FADP) and the General Data Protection Regulation (GDPR), you as the data subject have certain rights in relation to the processing of your personal data. These rights include:
Right of access (Art. 25 FADP / Art. 15 GDPR): You have the right to request confirmation as to whether we are processing personal data about you. If this is the case, you can request information about the processed data and further information, such as the processing purposes, the categories of data, the recipients and the planned storage period.
Right to rectification (Art. 32 FADP / Art. 16 GDPR): If your personal data is incorrect or incomplete, you have the right to request the immediate rectification or completion of this data.
Retention & Deletion · User right or choice
You can request erasure on specified grounds
The notice describes an erasure right under Article 32 FADP and Article 17 GDPR where data is no longer needed for its collection purposes, consent is withdrawn and no other legal basis exists, processing was unlawful, or deletion is legally required. Its retention section also recognizes applicable legal reasons, such as mandatory retention, that may prevent deletion; withdrawal is not presented as overriding statutory retention.
Supporting quotations
Right to erasure (right to be forgotten) (Art. 32 FADP / Art. 17 GDPR): You have the right to request the erasure of your personal data if one of the following grounds applies
The data is no longer necessary for the purposes for which it was collected.
You withdraw your consent and there is no other legal basis.
The data has been processed unlawfully.
The deletion is necessary to fulfill a legal obligation.
Where we have not explicitly stated a retention period in this privacy policy, the following applies: We will only process your personal data for as long as is necessary to achieve the purpose of the processing. As soon as the purpose of the processing no longer applies, we will delete your data immediately, unless there are legitimate reasons within the meaning of the applicable legal regulations (e.g. Art. 17 sec. 3 GDPR), such as in particular legally prescribed retention periods, to prevent deletion. In this case, the data will be deleted immediately after the retention period has expired.
Data that we process on the basis of your consent will be deleted immediately after you withdraw your consent, unless statutory regulations prevent deletion.
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.
Legal Rights & Agreement Rules · User right or choice
You can receive supplied data in a portable format
The notice describes a right under Article 28 FADP and Article 20 GDPR to receive the personal data you provided in a structured, commonly used, machine-readable format and request transmission to another controller where technically feasible. Its stated object is data you supplied, not an unconditional promise to port every item Wire holds.
Supporting quotations
Right to data portability (Art. 28 FADP / Art. 20 GDPR): You have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and to request its transmission to another controller, provided this is technically feasible.
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.
Legal Rights & Agreement Rules · User right or choice
You can complain to a competent data-protection authority
If you believe personal-data processing violates data-protection law, the policy describes a right to complain under Article 77 GDPR and Article 49 FADP. It names Switzerland’s Federal Data Protection and Information Commissioner and, in the EU, the competent authority in your country of residence.
Supporting quotations
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR / Art. 49 FADP): If you believe that the processing of your personal data violates data protection laws, you have the right to lodge a complaint with a competent data protection supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC); in the EU, you can contact the competent data protection authority in your country of residence.
Inference & Profiling · Company commitment
Wire rules out the specified form of automated decision-making
Wire says it does not use automated decision-making under Article 22(1) and (4) GDPR: web-based systems creating user profiles and making automated decisions with legal effects or similar detriment. This is a statement about that defined form of decision-making; it should not be read as denying all analytics or advertising-related processing described elsewhere.
Supporting quotations
We do not use automated decision-making in accordance with Art. 22 sec. 1 and 4 GDPR, i.e. we do not use web-based systems to create user profiles and make automated decisions based on them with legal effect or similar detriment to you.
Cross-references
narrows (model-proposed): Wire’s no-profiling statement sits alongside consent-based marketing — narrows: The specific automated-decision commitment concerns legal or similarly detrimental effects, distinct from the broader profiling wording and later marketing practices.
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.
Wire says the privacy policy may change from time to time and that the updated version will be available on the website. This paragraph does not promise individual notifications or a fixed advance-notice period.
Supporting quotations
This privacy policy may change from time to time, and we will make the updated policy available on the website.
Legal Rights & Agreement Rules · Context
Separate terms of service also govern the privacy policy
The policy directs readers to the terms governing the website and service and says those terms also govern the privacy policy’s terms. This source does not reproduce them, so their additional conditions cannot be inferred from this notice.
Supporting quotations
Please refer to the terms of service governing the use of the website and the service, as they also govern the terms of this privacy policy.
Not stated here
The referenced terms of service are not supplied with this source; their provisions, priority rules and effect on this policy cannot be determined here.
Legal Rights & Agreement Rules · Context
This policy covers Wire’s website, messenger, app and other services
The policy identifies Wire Swiss GmbH in Zug, Switzerland, as Wire and covers collection, processing and use of data across its website, messenger, app and other services. It states it was last updated in October 2025. Unless context requires otherwise, references to you include the organization using team management, its team administrator and its team members, as defined in the separate terms of service.
Supporting quotations
Last updated: October 2025
Wire Swiss GmbH, Untermüli 9, CH-6300 Zug ("Wire" or "we") is committed to protecting your data. With this privacy policy, we inform you about the collection, processing, and use of data in connection with our website ("Website"), our messenger ("Messenger"), our app ("App") and other services (collectively "Wire Services").
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).
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.
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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.
Legal Rights & Agreement Rules · Context
Swiss law governs Wire’s data processing; GDPR may also apply
Wire says its processing is subject to Swiss data protection law, including the Federal Data Protection Act, and that this notice provides information under Article 19 FADP. For individuals from the EU or EEA, GDPR may also apply. The notice does not say GDPR applies to every user.
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As a company based in Switzerland, Wire and its data processing activities are subject to Swiss data protection law, particularly the Federal Data Protection Act (SR 2351). This privacy policy covers the obligation of Wire for information according to Art. 19 of the Swiss Federal Act of Data Protection ("FADP"). For individuals from the European Union or the European Economic Area, the General Data Protection Regulation ("GDPR") may also apply.
Legal Rights & Agreement Rules · Procedure
Wire identifies its controller and privacy contacts
Unless this policy says otherwise, Wire Swiss GmbH, company number CHE 432.881.146, is responsible for processing data relating to Wire Services. Its address is Untermüli 9, CH-6300 Zug, Switzerland, and its contact email is legal@wire.com. Data protection inquiries may go to privacy@wire.com. The named DPO is Susanne Klein at Beiten Burkhardt Services GmbH, Ganghoferstraße 33, 80339 Munich, Germany.
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Any inquiries regarding your data, its protection, and how it is handled by Wire can be directed to the Data Protection Officer (“DPO”) at [privacy@wire.com](mailto:privacy@wire.com).
Unless otherwise stated in this privacy policy, Wire, a limited liability company under Swiss law, based in Zug (Switzerland), with the company identification number CHE 432.881.146, is responsible the processing of data related to the use of Wire Services. You can contact Wire as follows:
Wire names its EU representative and Swiss supervisory authority
Wire names Wire Germany GmbH, Rosenthaler Straße 41, 10178 Berlin, as its EU representative under Article 27 GDPR, registered as HRB 149847 with the Charlottenburg court. Its named supervisory authority is the Swiss EDÖB, Feldweg 1, 3003 Bern, telephone +41 58 462 43 95. The page also labels an EDÖB contact form.
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Wire designates Wire Germany GmbH, Rosenthaler Straße 41, 10178 Berlin, Germany, as its EU representative pursuant to Article 27 GDPR, registered under HRB 149847 with the local court of Charlottenburg.
Wire's supervisory authority is: Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB) Feldweg 1 3003 Bern Switzerland Phone: +41 58 462 43 95
Contact form for EDÖB
Legal Rights & Agreement Rules · Restriction or exception
Processing details apply when Wire is the controller
The listed collection purposes and legal bases apply only insofar as Wire controls the relevant processing. When Wire processes data on a customer’s instructions as a processor, it says it cannot give those purposes or legal bases; users should ask the controller, such as their employer.
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When you use Wire Services, the following personal data may be collected and processed for the purposes and on the legal basis specified below.
Please note that below information only applies to the extent that Wire is the controller for the relevant data processing. Insofar as Wire processes personal data on behalf of and on the instructions of a Wire customer (acting as a so-called data processor), Wire cannot provide any details on the purposes or legal bases of the data processing. Please refer to the relevant controller (e.g., your employer) for details on the data processing.
Cross-references
qualifies (model-proposed): Messenger conversations are end-to-end encrypted — qualifies: The purpose and legal-basis details apply when Wire acts as controller; customer-directed processing requires asking that controller.
Wire says it handles conversation content only as technically needed to provide the service. Text, voice and video chats and shared files and documents are encrypted on the sender’s device and decrypted only on the recipient’s device. Wire says it has neither encryption keys nor backdoors and cannot access conversations. Users can delete conversation content on their own device at any time; this passage does not promise deletion from other users’ devices.
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Wire transmits and processes the content of conversations from users of the Wire Messenger only to the extent technically required to provide the relevant services. The content of conversations is encrypted with strong encryption on the sender's device and decrypted only on the recipient's device (end-to-end encryption). This includes all text, voice, and video chats, as well as other files and documents shared in the conversations. Wire does not have access to encryption keys and does not use backdoors. Conversations belong to the users, and Wire has no access to them. Users may delete the content of the conversations on their device specifically and generally at any time.
Retention & Deletion · Company practice
Undelivered encrypted messages remain temporarily on Wire servers
Wire temporarily stores encrypted messages to deliver them when recipients come back online and says it deletes that server data immediately upon delivery. It also uses transport encryption for metadata. The stated basis is contract performance under Article 31(2)(a) FADP or Article 6(1)(b) GDPR. Transport protection for metadata is distinct from the stated end-to-end encryption of conversation content.
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Wire also uses transport encryption to secure metadata. Encrypted messages are temporarily stored on Wire's servers for delivery when users come back online. However, this data is immediately deleted from Wire’s servers as soon as the relevant message has been delivered to the recipient of the message. The legal basis for this data processing is Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (contract performance).
Retention & Deletion · Company practice
General logs have a 90-day limit; website visits have a specific rule
Wire collects technical logs on each service access to provide its services. With a service contract it cites Article 31(2)(a) FADP or Article 6(1)(b) GDPR contract performance; otherwise Article 6(1)(f) GDPR legitimate interests. The general logs section gives a maximum 90-day retention for troubleshooting, improvement and abuse prevention, citing Article 31(2)(a) FADP or Article 6(1)(f) GDPR for storage. The website section separately says visit data, particularly IP addresses, is deleted within 30 days unless an attack or threat by the user is recognized. The notice gives no separate deadline for that exception and does not expressly reconcile it with the general 90-day maximum.
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Technical data ("log files") is collected and processed each time the Wire Services are accessed. This data processing is necessary to provide the Wire Services. If the user has concluded a contract with Wire on the provision of the relevant Wire Service, the legal basis is Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR (contract performance). Otherwise, the legal basis is Art. 6 sec. 1 lit. f GDPR (legitimate interest), since Wire has a legitimate interest in the provision of Wire Services like our Website.
Logs are kept for a maximum of 90 days to assist troubleshooting, improve service, and prevent abuse. Wire has a legitimate interest in the securing and improving its services. Therefore, the legal basis for this storage is Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. f GDPR (legitimate interest).
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.
Not stated here
The policy does not explicitly state whether the website security exception remains subject to the general 90-day maximum.
Data Access & Collection · Company practice
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.
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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).
Not stated here
The general account and Messenger-specific required-field lists differ; the notice does not resolve whether a separate display name is mandatory for Messenger.
Account & Service Control · Company practice
Email verification and registration records help establish account ownership
Messenger registration uses an emailed verification code. If the email is not verified, the supplied data is deleted after one month. Wire may also store registration and verification dates and times and the registration device’s IP address to establish who registered an account or trace possible email misuse. It cites contract performance for this registration processing.
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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).
Charges & Financial Obligations · Company practice
Team purchases involve billing data and retention for tax obligations
Team accounts may require billing information shared with a billing provider. Purchasing admins must supply payment methods and possibly more account data; transaction amounts and other transaction information are processed. Wire uses it for billing and tax compliance. For direct customers it cites contract performance under Article 31(2)(a) FADP or Article 6(1)(b) GDPR; for others, such as employees of a customer, Article 6(1)(f) GDPR legitimate interests; tax collection and storage rely on Article 6(1)(c). The stated deletion period is within 12 months after contract termination or expiry of legal retention periods, so contract termination alone does not guarantee immediate deletion.
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For Team-Admin or Team-Member accounts, additional billing information may be required and shared with the billing provider. To make purchases, admins must provide payment methods and possibly additional account data. Some transaction-related personal information, such as transaction amounts, is also processed.
Wire processes the payment-related data for the billing of our customer's purchases and to comply with tax laws. If you are our customer, i.e. our direct contractual partner, the legal basis for the processing of the above-mentioned is contract performance according to Art. 31 sec. 2 lit. a FADP or Art. 6 sec. 1 lit. b GDPR. Otherwise, for example if your employer is our customer, the data processing is based on Art. 6 sec. 1 lit. f GDPR (legitimate interest), in which case Wire has a legitimate interest in the billing of purchases to its customers. Insofar as we collect and store data for tax reasons, the legal basis is Art. 6 sec. 1 lit. c GDPR (compliance with legal obligations). Data is deleted within 12 months after contract termination or expiration of legal retention periods.