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Legal
This privacy policy explains how Wowise (WOWISE - FZCO), a free zone company incorporated in Dubai Silicon Oasis, Dubai, United Arab Emirates, collects, uses, shares, and protects personal data. In the rest of this policy, "Wowise", "we", "us", and "our" mean that company.
Wowise publishes The Crossover, a free email newsletter about crypto and macro markets, and The Crossover Pro, its paid edition. Both are published on the Beehiiv platform and delivered through the website at thecrossover.io.
This policy applies to:
Where we run a competition, separate Official Rules govern entry, eligibility, and prizes. This is the privacy policy those Official Rules refer to.
Wowise is the controller of the personal data described in this policy. That means we decide how and why your personal data is used. We use service providers (described in section 6) that process data on our behalf and on their own systems, but responsibility for your data under this policy sits with us.
We aim to collect only what we need to run the service. In practice, that means:
Account and subscription data. Your email address. This is the only information you must provide to subscribe. You may optionally give us your name.
Survey and poll responses. If you complete our welcome survey or answer polls in the newsletter, we keep your responses. These are always optional.
Profile fields. We may store additional details about your subscription as custom fields on the Beehiiv platform, for example your subscription tier, sign-up source, or content preferences.
Referral data. Every subscriber gets a personal referral link. We record referral activity linked to it, meaning which new sign-ups were credited to your link, so we can operate the referral program fairly.
Payment data (The Crossover Pro only). Payments are processed by Stripe through the Beehiiv checkout. Wowise never receives or stores your full card number. We see limited billing details, such as the card type, the last four digits and the expiry date, and we receive your subscription status and billing metadata, such as your plan, renewal dates, and whether a payment succeeded or failed.
Contact and correspondence data. If you submit one of our contact forms (Get Involved, Ask Viv, or partner enquiries) or email us, we keep the message and our reply, along with the contact details you provide.
Usage data. Like almost all email newsletters, our emails contain a small tracking pixel that records whether an email was opened and which links were clicked. We also receive website analytics through Beehiiv, together with data derived from your device, browser, and IP address, such as device type and approximate location. Section 12 explains this in more detail.
Competition entry data. If you enter a competition, we collect the information described in that competition's Official Rules, typically your name, contact details, and, if you win, whatever is needed to deliver your prize.
Only your email address is required for the free newsletter. For The Crossover Pro, you also need to complete payment through Stripe. Everything else is optional, and the newsletter works fine without it.
We do not ask for, and do not want, sensitive personal data (such as health, political, or religious information). Please do not include it in survey answers or correspondence.
Directly from you. When you subscribe (sign-up is double opt-in: your subscription only becomes active once you click the confirmation link we email you), complete the welcome survey, answer a poll, use your referral link, submit a contact form, enter a competition, correspond with us, or check out for The Crossover Pro.
Automatically, through our platform. When you open or click our emails, or visit thecrossover.io, Beehiiv collects the usage data described above on our behalf.
From Stripe, as our payment processor. When you pay for The Crossover Pro, Stripe passes us your subscription status and billing metadata. Your card details stay with Stripe.
We do not buy subscriber lists or collect data about you from data brokers.
We only use your data for the purposes below. The legal bases in this table are stated for readers in the UK and the European Economic Area, where the UK GDPR and EU GDPR require us to identify one for each purpose.
| Purpose | Data used | Legal basis (UK/EEA) |
|---|---|---|
| Delivering The Crossover Pro and managing your paid subscription | Email address, name, subscription status, billing metadata | Performance of our contract with you |
| Sending The Crossover (free newsletter) after your confirmed, double opt-in sign-up | Email address, optional name, profile fields | Your consent, which you can withdraw at any time by unsubscribing |
| Honoring your unsubscribe and keeping you off our list | Your email address (a minimal suppression record) | Compliance with electronic marketing laws and our legitimate interests |
| Understanding readership and improving the newsletter (email measurement, surveys and polls) | Email open and click data, survey and poll responses | Our legitimate interests in understanding what readers value and improving our service (see section 12, including how to prevent this at any time) |
| Understanding how our website is used (website analytics) | Website analytics data, including device, browser, and IP-derived data | Your consent, collected through the cookie banner on our website (see the Cookie Notice at thecrossover.io/cookies) |
| Operating the referral program | Your referral link and referral activity | Our legitimate interests in running the program and crediting referrals fairly |
| Responding to contact-form submissions and correspondence | Contact details, message content | Our legitimate interests in responding to the people who write to us |
| Publishing testimonials and reader contributions you agree to share | Your name (as agreed with you) and the contribution | Your consent, which you can withdraw for future use |
| Keeping our services secure and preventing fraud and abuse | IP-derived and device data, usage data, subscription records | Our legitimate interests in protecting our subscribers and systems |
| Running competitions you choose to enter | Competition entry data | Performance of the competition contract set out in the Official Rules |
| Setting non-essential cookies and similar technologies | Cookie data (see the Cookie Notice) | Your consent |
| Keeping tax, accounting, and license records | Billing records, transaction metadata | Compliance with our legal obligations, and our legitimate interests in meeting obligations that arise under the law of our home jurisdiction |
We do not make decisions that have legal or similarly significant effects on you by automated means. We do group subscribers by engagement (for example, whether recent emails were opened) to manage our list and tailor what we send.
Where we rely on legitimate interests, we have weighed those interests against your rights and only proceed where we are satisfied the balance is fair. You can object to any processing based on legitimate interests (see section 9).
The newsletter is the product. When you subscribe, you are asking us to email you, and that is what we do. We do not run separate marketing campaigns beyond the newsletter itself, service messages about your subscription, and occasional mentions of The Crossover Pro within our emails.
Every email we send contains an unsubscribe link. Two things are worth understanding:
If you unsubscribe from all our emails while a paid subscription is still active, we will email you to confirm that your subscription is still running and to show you how to cancel it.
We share personal data only with the following recipients, and only to the extent needed:
We do not sell personal data. We do not give advertisers or sponsors access to your personal data, and we do not share it with third parties for their own advertising. If we ever publish sponsored content, the sponsor will not receive your personal data.
We are based in the United Arab Emirates, and our main service providers (Beehiiv, Stripe, and Google) process data in the United States. Your personal data will therefore be processed outside your own country, including outside the UK and the EEA if you are located there.
Where UK or EU law applies to a transfer, we rely on safeguards recognized by that law, such as standard contractual clauses forming part of our providers' data-processing terms. You can ask us at [email protected] for details of the safeguards that apply to a particular transfer and, where applicable, a copy.
Where we access personal data from the UAE, the protections described in this policy apply to that processing in full.
We keep personal data only as long as we need it:
If you are in the UK or the EEA, you have the right to:
If you are a California resident, the CCPA gives you rights over your personal information. In the preceding 12 months we have collected these categories of personal information: identifiers, such as your name and email address; commercial information, such as your subscription history; financial information (limited billing details such as card type, last four digits and expiry date); internet activity, such as email opens, clicks, and site usage; geolocation data (approximate location derived from your IP address); and inferences (engagement groupings, as described in section 4). We collect it from you directly, through automatic collection, and from our service providers, such as our payment processor; we use it for the purposes described in section 4, and we disclose it to the recipients described in section 6. We have not sold or shared personal information as those terms are defined in the CCPA in the preceding 12 months, and we do not use or disclose sensitive personal information.
As a California resident, you have the right to know and access the personal information we hold about you, to delete it, to correct it, to opt out of its sale or sharing (not applicable, since we do neither), to limit the use of sensitive personal information (not applicable, for the same reason), and not to be discriminated against for exercising any of these rights. You may use an authorized agent to make a request, and we will verify requests before acting on them. Because we do not sell or share personal information, opt-out preference signals such as Global Privacy Control do not change how we process your data.
If you are in the UAE, note that Wowise is established in the UAE and is subject to the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). If you are in the UAE, you have rights of access, correction and deletion under that law, and you may complain to the UAE Data Office.
If you are elsewhere, you may have similar rights under your local law, such as equivalent laws in Australia and other jurisdictions. We aim to honor reasonable privacy requests from any subscriber, wherever you live.
How to exercise your rights. Email us at [email protected]. To protect your data, we may need to verify your identity first, usually by asking you to write from the email address on your subscription or to confirm details only the subscriber would know. We respond within the timelines required by applicable law: generally one month for UK and EEA requests and 45 days for California requests, in each case extendable where the law allows for complex requests, in which case we will tell you.
The simplest rights need no email at all: every newsletter contains an unsubscribe link, and you can update your details through the preference links in our emails.
The Crossover and The Crossover Pro are not directed at anyone under 18, and our terms require subscribers to be 18 or over. We do not knowingly collect personal data from anyone under 18. If you believe someone under 18 has subscribed or given us their data, contact us at [email protected] and we will delete it.
We protect personal data using appropriate technical and organizational measures, applied largely through our platform providers: Beehiiv, Stripe, and Google each maintain security programs including encryption of data in transit and access controls, and we limit access to subscriber data to those who need it. No method of transmission or storage is 100% secure, so we cannot guarantee absolute security. If a personal-data breach occurs that affects you, we will notify you and the relevant authorities where and when applicable law requires it.
Email tracking. Our emails contain a small tracking pixel, a tiny invisible image that loads when you open the email, and tracked links that record which links you click. Together these measure opens and clicks, along with basic technical details such as device type and approximate location derived from your IP address. We use this to understand what readers value and to manage the health of our list, and we rely on our legitimate interests to do so (see section 4). You can prevent open tracking at any time by blocking remote images in your email app, and you can avoid click tracking by typing links directly into your browser instead of clicking them. Unsubscribing stops all measurement.
Cookies. Our website uses cookies and similar technologies. These are explained in our Cookie Notice at thecrossover.io/cookies, which also describes how to manage your preferences and how we obtain consent for non-essential cookies.
Advertising pixels. We do not currently use any advertising pixels (such as the Meta pixel) on our website or in our emails. If we introduce one in future, we will update this policy and the Cookie Notice first, and we will seek your consent where the law requires it, before it is switched on.
We may update this policy from time to time, for example when we change providers or add features. The version published at thecrossover.io/privacy is the current one and applies to our processing from the date we post it. If we make a material change, we will tell you by email or by a prominent notice on thecrossover.io before the change takes effect. Where a change requires your consent under applicable law, we will ask for that consent before the change applies to you.
For any question, request, or complaint about your personal data or this policy, email us at [email protected].
We encourage you to contact us first with any privacy concern: most issues can be resolved quickly and directly. Doing so never limits your rights, and you remain free to complain to the UK Information Commissioner's Office, your local EU data-protection authority, or any other regulator with authority over you, at any time.