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RESEARCH PRIVACY POLICY



Last Updated: 05/10/2023

This Research Privacy Policy (“Policy”) explains what you can expect from Wise
regarding the processing of your personal data and our requirements if you take
part in a research project. Please read this statement carefully: it’s legally
binding and addresses useful information on how we use, store, share and keep
your data safe.

We take the privacy and protection of your data very seriously and are committed
to handling Personal Information responsibly and in a way that meets the legal
requirements of the countries in which we operate.

For more detailed information on how we process Personal Data in different
jurisdictions, please go to Wise Global Privacy Policy. In case of
contradictions between this Research Privacy Policy and Wise Global Privacy
Policy, the latter shall prevail.

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1. RESEARCH AT WISE

2. DATA CONTROLLER

3. INFORMATION WE COLLECT AND PROCESS ABOUT YOU

4. PERSONAL DATA SHARING

5. DATA RETENTION

6. YOUR RIGHTS

7. CONTACT US

8. TERMS AND DEFINITIONS

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1. RESEARCH AT WISE

We conduct research to learn directly from our users, to better understand what
their needs are. Those insights are then used in the design process for products
and services, so we can improve experiences for all our customers.

User Experience research can take place via interviews, testing sessions,
surveys to collect user feedback and other similar methods.

Before taking part in the Research Interview, you will be asked to sign a
Research Consent Form. In some specific cases, you may also be asked to sign a
Research Non-Disclosure Agreement (NDA).

When you agree to take part in a Research Project, we will use your personal
data for the sole purpose of conducting the research. Such data will then be
analysed to help improve our products and services.




2. DATA CONTROLLER

The Data Controller for the collection, processing and use of personal data is
Wise Payments Limited (“Wise”, “us”, “we”, “our'') an international business
with headquarters on the 6th Floor of The Tea Building, 56 Shoreditch High
Street, London E1 6JJ. Our registration number with the Information
Commissioner’s Office UK (ICO) is Z2976089. If you have any questions about how
we protect or use your data, please email us at privacy@wise.com.




3. INFORMATION WE COLLECT AND PROCESS ABOUT YOU

Research Projects may have different objectives and different requirements. So,
the personal data we collect and process can vary. We only collect and/or
process the information that is essential for the purpose of the research.

Research at Wise takes different forms:

Surveys:

We rely on Legitimate Interest to send you a Survey. This can be:

 * a study itself.
 * a part of an invitation email for a Research Project. In this case, we may
   ask you to provide some Personal Information, such as Demographic Data (e.g.
   age, gender, education, income, marital status), Psychographic Data (e.g.
   activities, hobbies, interests, and opinions), Geographic Data and
   Behavioural Data (i.e. how and how often do you use our products or
   services).

We collect the information above to ensure that:

 * you meet the research criteria.
 * we meet our standards for diversity and inclusion.

Interviews / Online sessions

If you meet all the criteria for the Research Project, you may be invited to
participate in an online video session in the form of a Zoom interview. With
your consent, we collect the following Personal Data in order to document the
session:

 * video and photographic recordings of your face when taking part in the
   Research Project (this may include screen recordings of your demonstration
   using Wise, digital devices and your opinion on designs).
 * audio recordings of your voice.




4. PERSONAL DATA SHARING

We may use external providers to book a venue for research or for conducting
remote sessions. We may also use the following providers, only where necessary,
to conduct research, to collect, transcribe or analyse your personal data:

 * survey tools.
 * video conference tools and whiteboard tools.
 * transcription services, including automatic transcription on analysis tools.
 * scheduling tools.
 * consent management tools.
 * in-app/ on-the-website surveys.

If we rely on external providers for developing research, we will monitor and
limit their access to your personal data. Please note that, in those cases, the
provider’s Privacy Policy and Terms and Conditions may apply.

You will be notified before being directed to their pages to continue the
research process. Below, you can see our trusted providers:

 * UserTesting usertesting.com
 * SurveyMonkey surveymonkey.com
 * Informizely informizely.com
 * Optimal Workshop optimalworkshop.com
 * Calendly calendly.com
 * Zoom zoom.us
 * GoogleMeet meet.google.com or calendar.google.com
 * DocuSign docusign.co.uk or docusign.com
 * BHN Rewards bhnrewards.com or app.rybbon.net or myprepaidcenter.com
 * QuestionPro questionpro.com

We will monitor and limit these third parties’ access to your data and ensure
the appropriate data protection agreements are in place.

Please note that in the scope of this Policy, we will never:

 * sell or rent your Personal Data.
 * process personal data outside the scope of the specified research.
 * share your Personal Data with Third Parties for marketing purposes.




5. DATA RETENTION

We will keep the Personal Data collected, stored, and processed for the aim of
the research for up to three (3) years.

Wise is committed to retaining your Personal Data safely; if you need more
information on how we store your personal data and controls in place, please
reach out to uxresearch-ops@wise.com




6. YOUR RIGHTS

In relation to the Personal Data we collect for the purpose and in the scope of
the Research, and with some country-specific variations, you have the right to:

 * Request a copy of the personal data we hold about you and to check that we
   are lawfully processing it.
 * Request correction of your personal data.
 * Request deletion of your personal data. For the purpose of the Research, we
   retain personal data for up to 3 (three) years; please note that deletion may
   not be possible if the data was already anonymised or the recording has
   already been deleted.
 * Withdraw your consent for us to process data, where our lawful basis for
   processing is based on that consent (please go to Section 3 of this Research
   Privacy Policy for more details on our Legal Basis).
 * Object to any processing based on the Legitimate Interests ground when there
   is something about your particular situation where you feel processing, on
   this ground, impacts your fundamental rights and freedoms (please go to
   Section 3 of this Research Privacy Policy for more details on our Legal
   Basis).
 * Request to suspend the processing of your personal data in the following
   situations: (i) if you want us to determine the data's accuracy; (ii) where
   our processing of the data is unlawful, but you do not want us to delete it
   at this time; (iii) where you wish us to retain the data even if we no longer
   require it because you need it to establish, exercise or defend legal claims;
   or (iv) you have objected to us using your data, but we need to confirm
   whether or not we have overriding legitimate grounds to continue using it.

For more details on how you can exercise your privacy rights, please get in
touch with the User Experience Team at uxresearch-ops@wise.com.




7. CONTACT US

Please send any questions, comments or requests regarding this Policy to our
privacy team at privacy@wise.com. You can also write to us at the following
address: Wise Payments Ltd, 6th Floor of The Tea Building, 56 Shoreditch High
Street, London E1 6JJ.

If you feel that we have not addressed your questions or concerns adequately,
you can file a complaint with the Information Commissioner or your Data
Protection Authority of reference.




8. TERMS AND DEFINITIONS

The following terms are defined as per the General Data Protection Regulation of
2016.

Behavioural Data Information generated by, or in response to, a customer’s
engagement with a business. Data Controller The entity which determines the
purposes for which and the means by which personal data is processed. Data
Processor Any natural or legal person, public authority, agency or other body
which processes personal data on behalf of the controller Data Processing Any
operation or set of operations performed on personal data. Processing includes
storing, collecting, retrieving, using, combining, erasing and destroying
personal data and can involve automated or manual operations. Data Sharing The
practice of disclosing personal data to Third Parties outside the Data
Controller organisation. It can also cover the sharing of personal data between
different parts of an organisation or other organisations within the same group
or under the same parent company. Demographic Data Information referring to
socioeconomic information, including employment, education, income, marriage
rates, birth and death rates. GDPR General Data Protection Regulation (EU)
2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data and
on the free movement of such data. Geographic Data Information having an
implicit or explicit association with a location relative to Earth. Legitimate
Interest Legal base for Personal Data Processing as per Art. 6 GDPR. Legal
person Any company, organisation, society and similar legal entity. Natural
person Any living human being. Non-Disclosure Agreement (NDA) A legally binding
contract that establishes a confidential relationship. Personal Information Any
information that relates to an identified or identifiable living individual.
Psychographic Data Information about a person's values, attitudes, interests and
personality. Research Consent Form The consent form provides potential
participants with written information to decide whether to participate in a
research study or not based on an explanation of the proposed research and the
nature of the participation. Research Interview Qualitative research method. A
researcher asks participants questions to gain an understanding of their
preferences, thoughts and feelings about the product/service/design. Research
Project A Research Project determines the viability of a new or existing service
or product through research conducted directly with potential or existing
customers. A company collects opinions and other feedback from consumers about
their interest in the product or service that helps make the best product
decisions. Every Research Project has different objectives and can use different
research methods. Data Retention Amount of time personal data will be kept for.
Third-Party A natural or legal person, public authority, agency or body other
than the data subject, controller, processor and persons who, under the direct
authority of the controller or processor, are authorised to process personal
data. User Experience (UX) The overall experience of a person using a product
such as a website or computer application, especially in terms of how easy or
pleasing it is to use.


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