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20under20 Privacy Policy

Last Updated: 16 February 2022

Version Number: 1.0

This Privacy Policy (“Policy”) is an overview of how we collect, use, and process your personal data when you take part in the 20 Under 20 competition or interact with us via our web page https://payout-surge.live/campaign/20under20%3C/a%3E. For information on the collection, use and processing of your data by Wise more generally, please refer to our main privacy notice here.

Please read this Policy carefully, as it becomes legally binding when you use our Services. For the full definition of the capitalised words here, check our Customer Agreement. We take privacy and protection of your data very seriously and are committed to handling the personal information of those we engage with, whether customers, suppliers or colleagues responsibly and in a way that meets the legal requirements of the countries in which we operate.

1. Data Controller

2. Data we collect about you

3. How we protect your personal information

4. Ways we use your information

5. Disclosure of your information

6. Sharing and storing your personal data

7. Data Retention

8. Your rights

9. Third-party links

10. Changes to our privacy policy

11. Contact

1. 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.

2. Data we collect about you

Personal data, or personal information, means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. We will collect and process personal data about you as follows:

2.1 Information we collect from you

  • You may give us information about yourself when you sign up to enter our competition or sign up for more updates on 20 under 20, e.g. when you provide us with personal details including your name and contact details as well as answers to competition entry questions about your business and you as an entrepreneur. This also includes information you provide through your continued use of our Services, your participation in discussion boards or other social media functions on our Website or App relating to this competition, on Wise's social media channels and website.
  • If successful, your picture may be taken for use in press releases relating to the competition. The content of your communications with us, which we collect via google forms, emails and other means.
  • Please ensure that your personal data is current, complete and accurate by updating it whenever necessary.

2.2 Information collected from social networks:

  • If you submit your video application via social media (for instance Facebook, YouTube, TikTok or WeTransfer), the social network will provide us with access to certain information that you have provided to them, including your name, profile image and email address, in accordance with the social network service provider’s privacy policy. We use such information, together with any other information you directly provide to us when registering your application when reviewing your submission.

3. How we protect your personal information

+3.1 We take the safeguarding of your information very seriously. The transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to ensure it stays secure, including:

  • Communication over the Internet between you and Wise systems is encrypted using strong asymmetric encryption. This makes it unreadable to anyone who might be listening in.
  • We update and patch our servers in a timely manner.
  • We run a Responsible Disclosure and bug bounty program to identify any security issues in Wise services.
  • Our technical security team proactively monitors for abnormal and malicious activity in our servers and services.
  • We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards (including obligations to protect any information and applying appropriate measures for the use and transfer of information).
  • When information you’ve given us is not in active use, it is encrypted at rest. This means it’s unreadable without the decryption key. You can find out more from our Security page.

3.2 We are regularly audited to confirm we remain compliant with our security certifications, including SOC 2 and PCI-DSS. As part of these audits, our security is validated by external auditors.

+3.3 We restrict access to your personal information to those employees of Wise who have a business reason for knowing such information and third party service providers’ processing data on our behalf. All Wise employees who have access to your personal data are required to adhere to this Policy and all third-party service providers are requested by Wise to ensure appropriate safeguards are in place (including non-disclosure agreements). In addition, contracts are in place with such third-party service providers acting as data processors for Wise that have access to your personal data, to ensure that the level of security required in your jurisdiction is in place, and that your personal data is processed only as instructed by Wise.

3.4 We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, technical and organisational safeguards that comply with applicable laws and regulations to protect your personal information from unauthorised access.

4. Ways we use your personal information

4.1 Lawful basis: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have given us your consent to process your data;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • Where we have a legal obligation to process your personal data to comply with laws, regulations or court orders;
  • Where it is necessary to fulfil our obligations under a contract with you;
  • Where it is necessary to protect the vital interests of yourself or other individuals

4.2 Purposes for which we will use your personal data: the ways we plan to use your personal data are described below, including which of the legal bases we rely on to do so in the UK and the EU. We have also identified what our legitimate interests are where appropriate.

  • to assess your entry and to choose a competition winner

Lawful basis for processing, including basis of legitimate interest: To fulfil our obligations under a contract with you

  • to provide you with information and updates on the competition and send you other administrative information or request additional information relating to your application

Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to keep our records up-to-date and keep you updated if you enter the competition)

Where you’ve consented for us to process your personal data in a certain way

  • to use your personal information in press releases relating to the competition if you are a finalist or win the competition

Lawful basis for processing, including basis of legitimate interest: Legitimate interest (to publicise Wise, the competition and the winner)

5. Disclosure of your personal data

5.1 We may share your personal data with third parties, including:

  • Judges that will be assessing your business as part of the competition;
  • our group entities and subsidiaries; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our site.

5.2 We may disclose your personal information to third parties including:

  • affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
  • in the event that we sell or any business or assets or combine with another organisation, in which case we may disclose your personal data to the prospective buyer of such business or assets or prospective organisation with which our business or assets may be combined;
  • in response to a subpoena, warrant, court order, properly constituted police request or as otherwise required by law;

5.3 We do not have a list of all third parties we share your data with, as this would be dependent on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to privacy@wise.com.

6. Sharing and storing your personal data

6.1 We may transfer your data to and and store it in countries outside the UK and European Economic Area ("EEA") which do not offer an equivalent level of protection to your country. It may also be processed by staff operating outside the UK and EEA. Such staff may be engaged in activities that include the fulfilment of your payment order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

6.2 In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 5 that are based outside of the UK and EEA. In these cases, we ensure that appropriate safeguards, including Standard Contractual Clauses, are in place.

7. Data retention

7.1 We will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it. We only access your data internally on a need to know basis, and we’ll only access or process it if absolutely necessary.

7.2 We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate. We do this automatically, so you don’t need to contact us to ask us to delete your data.

7.3 If your application is unsuccessful, your personal data will be deleted within 1 year of your entry.

7.4 Finalists and winners data will be stored for up to 10 years, after which point they will be deleted.

8. Your rights

8.1 Subject to applicable laws, you may have certain rights regarding the information we hold about you. Your rights can be exercised in accordance with the relevant data protection legislation. If you have any questions in relation to our use of your personal information, contact us. You may 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 the personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.
  • Ask us to delete personal information where there is no good reason for us to continue to process it. You may also have the right to ask us to delete your personal data where (i) you have successfully exercised your right to object to processing (see below), (ii) where we may have processed your information unlawfully or (iii) where we are required to delete your personal data to comply with local law. We may not always be able to comply with your deletion request for specific legal reasons which will be notified to you, if applicable, in our response to your request;
  • Withdraw your consent for us to process data, where our lawful basis for processing is based on that consent. Note that withdrawal of consent does not affect the lawfulness of processing which may have taken place prior to withdrawal of consent. If you withdraw your consent, we may not be able to provide certain products or services to you;
  • Request us to cease direct marketing to you, by contacting us or adjusting your notification preferences in the settings section of your account;
  • 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.
  • Ask us 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 over-riding legitimate grounds to continue using it.
  • Request the transfer of your personal data to a third party or yourself. We will provide you or your chosen third party with the personal data you provided to us in a structured, commonly used, machine-readable format. This right applies only to information where we used the information to perform a contract with you or where you initially consented for us to use it.

8.2 Your exercise of these rights is subject to certain exemptions to safeguard the public interest (including the prevention or detection of crime) and our interests (including the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.

9. Third-party links

9.1 Our Services may, from time to time, contain links to the websites of our partner networks, advertisers and affiliates. Please note that these websites have their own privacy policies and that we do not accept any responsibility for them, so if you follow a link, check these policies before you submit any personal data to these websites.

10. Changes to our privacy policy

10.1 To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Policy at any time without notice by posting a revised version on this website. To stay up to date on any changes, check back periodically.

11. Contact

11.1 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 Limited, 6th Floor of The Tea Building, 56 Shoreditch High Street, London E1 6JJ.

11.2 If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws. In the United Kingdom this is the Information Commissioner’s Office at www.ico.org.uk.