Jump to section:
- Information we collect
- How We use information We collect
- Information Security
- The rules and guidelines we follow
- Keeping your data up to date
- Unsubscribing from services
These definitions should be used together with and considered as an extension of the SOLDO BUSINESS TERMS AND CONDITIONS Definitions
“Cookies”: small files of letters and numbers that are downloaded on to your computer when you visit a website. Cookies are used to carry out a number of tasks, for example remembering information such as your preferences and counting the number of people visiting a website.
“Personal Data”: any data which relates to you, if you can be identified from it (or from other data that is or is likely to come into the possession of the business who determines the purposes and the manner in which the data is processed). The business may be Us and the issuer of your Soldo Card – Wirecard Solutions Limited.
“SSL/TSL” (Secure Sockets Layer, Transport Layer Security): a protocol to set up secure encrypted communications to protect data in transit, for example, when transferring data between your computer and our secure server. In this document, SSL/TSL means also the usage of a proper level of encryption that avoids not authorised parties to decrypt communications considering the state of the art of technology and cryptography.
“We”, “us”, “Our” and “Soldo” means Soldo Financial Services Ltd. (Company No. 09495650) whose contact address is BOX 324, 19-21 Crawford Street, W1H 1PJ London, United Kingdom.
“User” relating to the Account, means (i) any person that has a relationship with the Legal Person, including but not limited to officers, directors, employees, consultants and contractors or (ii) a specific purchase category (e.g. office expenses, travel expenses) that has been assigned to the Account and to the Soldo Services available to that Account by the Authorised User.
“You”, “Your” means the Legal Person who has registered with and has opened a Soldo Account.
See http://www.ico.org.uk/ for more information on cookies and personal data. It sets out your rights and an organisation’s responsibilities when using them.
To operate Soldo Services we collect the following data:
Information you provide to access Soldo Services: to open and operate a Soldo Account and use the Soldo Services, you must provide, if required, the following about You and each User; name, address, date of birth, place of birth, country of birth, mobile phone number, email address, Country tax code, country of residence, delivery address, nationality, tax residency and credit or debit card or bank account information. So that we can check your identity, we will require further information such as, but not limited to, a copy of your passport or driving licence information and recent utility bills. This is required for us and our partners (only to the extent they are involved in providing a Soldo service to you) to comply with anti-money laundering legal obligations.
Information you provide in contact/correspondence with Soldo: We will use the Personal Data you give to us to send you communications about the Soldo Services.
Information About You From Third Parties: We use the Personal Data you provide to verify your identity. To do so we shall share it with identity check processors and/or credit reference and fraud agencies. In the course of such verification, we may receive other personally identifiable information about you from such services providers. A record of such enquiries may be left on your file, however they will not affect your credit rating.
We may also disclose your Personal Data as required by law, regulation or any competent authority or agency also to investigate possible fraudulent, unlawful or unauthorised activity.
Media: (should you choose to enable these features once available): for example if you use the Soldo Client, your profile picture you have stored so other Soldo users can identify you. The image you assign to your profile, or that of an Authorised User is solely your responsibility together with any other images that are tagged to transactions or capture receipts.
Technical information collected when you use Soldo Services: e.g. Identifier information collected when visiting Soldo’s website (see “How we use the information we collect” section for further information on cookies), Internet protocol address, browser type, operating system, browser language, timezone, service provider, system settings, system tokens/keys, Information about activities you undertake, such as the pages you visit, searches you make, marketing or links you click and mobile device information, such as a unique device identifier, operating system version, mobile carrier.
If you enable features of Soldo that are location-enabled, we may collect and process information about the location of your device. You will only be able to use location-based services if you have opted-in to do so and you will be able to disable such facility at any time.
Usage data: e.g. Information related to individual transactions e.g. loading information: time and date of load, load type. Purchase information: retailers used, items purchased, value of transactions. Withdrawals: ATM used, how much has been withdrawn.
Soldo Services usage information: e.g. pages visited, functions selected.
Communications between Soldo and Users or directly between Users: communications via Email, SMS, Soldo Client from Soldo to Soldo Users.
Questionnaires, Surveys, and Profile Data: From time to time, we offer optional questionnaires, surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. If we collect personally identifiable information from you in these questionnaires, surveys, you will be given notice of how the information will be used prior to you participating.
Referrals: if you submit contact information to us on a refer a friend or family basis to use Soldo Services. In doing so you are doing so represent that you have the consent of anyone whose contact information you provide for this purpose.
We use the information we gather to us to provide the Soldo Services and to better understand your use of the Soldo Services.
Internal Uses: We collect, store and process your information on servers located in the EEA. Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your Personal Data to:
· process transactions and provide the Soldo Services;
· verify your identity, including during account creation and password reset processes;
· resolve disputes, collect fees, and troubleshoot problems;
· manage risk, or to detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities;
· comply with law or a court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Soldo, our employees, our customers, or others;
· to carry out our obligations to you or any other users of Soldo Services, perform any services you have requested and allow you to participate in interactive features of the service when you choose to do so. For example if you contribute money to a User’s account we may communicate data about you and your gift to the relevant Account holder (parent / legal guardian) and to any User related to this;
· detect, prevent or remediate violations of Soldo policies or applicable user agreements;
· provide you with customer care services;
· improve the Soldo Services by customising your user experience;
· measure the performance of the Soldo Services and improve their content and layout;
· manage and protect our information technology infrastructure;
· provide targeted marketing and advertising, provide service updates, and deliver promotional offers based on the communication preferences you have defined for your Soldo Account; and
· perform creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties.
Questionnaires, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use such information to improve Soldo Services, send you marketing or advertising information, or as otherwise explained in detail in the survey itself.
Our contact with Soldo Customers: We communicate with our users on a regular basis via email, sms, live chat, messaging apps, or Soldo Client communication to provide requested services. We also communicate with our users by phone to:
· resolve customer complaints or claims made by users;
· respond to requests for customer service;
· inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
· confirm information concerning a user's identity, business or account activity; carry out collection activities;
· conduct customer surveys; and
· investigate suspicious transactions.
When you contact the Soldo Customer Care for assistance via any means we may keep a record of your communications to respond to your query and to improve our service to you. Your call may be recorded for training or quality purposes.
The Soldo Customer Care may contact you proactively to assist you with our service, for example if you have ordered a Soldo Card but have not managed to activate it or we notice you are having difficulty using a part of the Soldo Service such as using your Soldo Card at the point of sale.
We may use your contact details to send communications to you for the following reasons:
· Provide you with essential services communications, e.g. suspicious activity on your account, billing, responding to enquiries, etc.;
· Send you usage alerts to notify you of relevant account activity, e.g. allowance switched on/off, attempted card use at non-permitted merchant;
· Send you optional Soldo updates to let you know about changes to Soldo Services; and
· Inform you of relevant offers and other marketing-related items provided we have your prior consent to do so.
In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
We will disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in London. However, this aggregated information will not contain any Personal Data.
With Other Soldo Users:
If you use the Soldo Client, we may share your picture that you have stored with your Soldo Client with other Soldo Users so that they can identify you.
With Other Third Parties:
Soldo understands the importance of keeping your Personal Data secure. We will take appropriate technical and organisational measures to protect against unauthorised or unlawful processing, accidental loss or destruction of, or damage to Personal Data, although we cannot guarantee these things will never happen.
The measures we take to protect your Personal Data are set out below:
- Using industry standard security technology and procedures to protect your information
· High-security password protection on internal Soldo systems
· Encryption of our services using SSL/TSL (Secure Sockets Layer, Transport Layer Security)
· Training of our employees on information security
· Continual review of our policies and procedures in response to advances in technology and security best practice
- Soldo Client access Company ID, password and passcode protection
· We have built in a Company ID, password and Passcode protection on the Soldo Client for you and any of your Users to access to Your Soldo Account
- Limiting access to your data
· Access to Soldo systems is limited to approved Soldo team members only
· All employees undergo data protection training and are required to sign confidentiality agreements, to preserve the confidentiality of Personal Data.
We encourage you and Users to read and follow the security measures asked of you in your Soldo Business Account Terms and Conditions and its Annexes relating to your Company ID, Passcode, and Card PIN to ensure on-going security of the Soldo Services.
We do not recommend PINs, Company ID, Password or Passcode are written down. If they are, they must be kept securely and separately from your Soldo Card, any Soldo Account information and the device that you or any User uses to access the Soldo Client.
Location of your data
Soldo’s servers are located inside the European Economic Area (EEA) and some of the tools and services we use may be hosted outside the EEA. We want you to be aware that if we transfer your Personal Data to a service provider or agent in another country outside of the European Economic Area, we will make sure that the same levels of protection for Personal Data are in place between us and such service provider or agent as are required under by the UK data protection laws and that your information will only be processed by such service provider or agent for the purpose of providing the Soldo Service.
Some of your Personal Data you give to Soldo may be transferred outside the EEA. When this occurs and your Personal Data is sent to the US, Soldo ensures that the receiving organisations are part of the EU-US Privacy Shield scheme. Participating companies to the EU-US Privacy Shield scheme are listed in the public register available at https://www.privacyshield.gov/list.
Soldo is registered with the Information Commissioner’s Office and we have developed our internal data protection policies to comply with data protection laws.
You and any User can view Personal Data by logging into Your Soldo Account. For security reasons, certain types of information cannot be changed or deleted online. To amend this information you will need to contact us (see “Contact us” page) so we can verify your identity and the amendment you wish to make before the change can be made.
Please be aware that for legal or risk reasons the Soldo Customer Care may be unable to amend or delete certain types of data immediately. Your Personal Data will be stored by us for a period of 6 years after your Soldo Account has been closed.
In addition, we use back-up systems to prevent service interruptions or data loss. We cannot guarantee that your data will be changed or deleted in those archives.
You have the right to request a copy of the Personal Data that we hold about you and have the right to request that incorrect information is amended. To do this, you will need to contact us. We may charge a reasonable administration fee of up to £10 to provide a copy of your information. As before please remember that for legal or risk reasons we may be unable to amend or delete certain types of data. We will inform you of this following your request should this be the case.
Essential service and usage alerts
Soldo may communicate with you, User about important activity which has taken place on your account, for example, to alert you about suspicious transactions or problems with your account and send you alerts regarding your Soldo account usage, for example, when money is loaded or a Transaction occurs. These notifications are designed to keep you informed about important account activity, and may alert you to suspicious activity. We strongly advise that you enable Soldo notifications function within your device to fully benefit from the Soldo Services however, you will always maintain the option to disable this function within the settings of your device.
Marketing (opt in/out)
If You have previously consented to marketing emails, but no longer wish for You or any User to receive marketing communications, You can do so by using the unsubscribe link which will be at the bottom of any marketing emails we send.
All notices to unsubscribe from marketing emails will usually take 5 working days to process but please allow up to 2 weeks to take account of pre-prepared mailing lists.
We are committed to ensuring that all website visitors’ privacy is protected and that you have a positive experience. However, if you’d like to, you can change your Cookie settings at any time, details of how to do this can be found later in this section. The majority of Cookies are there to support processes and will expire when the browser is closed. Any persistent cookies are to improve user experience.
What’s a cookie?
If Cookies are enabled, during the course of any visit to our website, the pages you see, along with a Cookie, are stored to your device. On a repeat visit our website may check to see, and find, any Cookie left there from the last visit – this enables us to present personalised features. We might also look at IP addresses to add general information about the country, city or region in which you’re located, along with your domain (e.g. what internet service provider you use).
Cookies cannot be used by themselves to personally identify you. They can be used for marketing purposes, to create a profile of your engagement with we Group websites and if you have already given some personal details, to track your activity on our websites.
The exception to this is within our secure website where we have to securely identify you and track your usage to protect your Soldo Account. Cookies themselves don’t contain any personal or identifiable information about you.
Information supplied by Cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience.
We use the following cookies on our websites:
Control cookie settings
Most browsers will have a default ‘medium’ cookie setting, allowing those cookies to be used that directly relate to the website you are browsing but blocking third party cookies. You can change your cookie settings, and remove specific cookies, via your browser in the following way:
Internet Explorer: Tools > Internet Options > Privacy
Firefox: Tools > Options > Privacy
Google Chrome: Settings > Privacy > Content Settings
To opt-out of cookies that are not in our control such as Google cookies you must visit the weblink provided in the table.