Effective Date: [01.03.2017] Ver 1.2
Soldo Financial Services Ltd. BOX 324, 19-21 Crawford Street, W1H 1PJ London, UK (Company No: 09495650) www.soldo.com

Privacy Policy for Soldo Services

Jump to section:

  1. Definitions
  2. Introduction
  3. Information we collect
  4. How We use information We collect
  5. Information Security
  6. The rules and guidelines we follow
  7. Keeping your data up to date
  8. Unsubscribing from services
  9. Cookie Policy
  10. Accountability

How this Privacy Policy applies to you

Please view, read, download and save this Privacy Policy.

This Privacy Policy governs your use of the products and services offered by Soldo, which include the Soldo Account and Services the Soldo Client which together we shall refer to as  “Soldo Services”.  We may add other products and features in time, if so and unless we tell you otherwise, these products and features will also be covered by this Privacy Policy.

When you sign up for, access, or use of the Soldo Services you acknowledge that the terms in this Privacy Policy will apply and we shall take this as acceptance by you of the Privacy Policy.

1. Definitions

These definitions should be used together with and considered as an extension of the SOLDO ACCOUNT AND SERVICES 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, or another issuer of your Soldo Card – Paysafe Financial Services 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 any person (the Account Holder, an Internal User of the Account or an External User of the Account) who has been granted access to the Account by the Account Holder.

“You”, “your” means you the Soldo Account Holder and any User linked to your Soldo Account.

“Young Person” means an User of our service linked to the Soldo Account  aged between 8 years and 18 years.

We act as a data controller which means we determine the purpose for which Personal Data we collect is processed.  The nature of the Personal Data we collect and the purpose for which we use it is set out in this Privacy Policy. Each of our partners, to whom we transfer Personal Data (list attached) may also be data controllers of personal data and have their own privacy policies

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.

2. Introduction

This Privacy Policy describes the information we collect and how we use that information. We take the processing of your information seriously and will use your information only in accordance with the terms of this Privacy Policy.

Our Privacy Policy may be revised over time as new features are added to the Soldo Services or as we strive to improve our service. If we change this Privacy Policy, we will do so by notifying you by email and/or through our Soldo Client notification.  We will also post a revised version of it on our Website. Unless we are legally required to do otherwise, we will provide you with at least 60 days’ prior notice of the changes to this Privacy Policy.  If you are not happy with the proposed changes, you can contact us at any time during the 60 day period and terminate your use of the Soldo Services without charge. If we do not hear from you during this time, you will be deemed to have accepted the changes to the Privacy Policy and the revised Privacy Policy will replace this version and shall apply to you from the date it becomes effective.   

You should check this website regularly for the most current version of our Privacy Policy.

You agree to this Privacy Policy at the time you register with Soldo, use the Soldo Services or use the Website.  If you have any questions regarding its content, please contact the Soldo Customer Care (see “Contact us” page). If you disagree with any of the terms of this Privacy Policy, please do not register for or use the Soldo Services or use this website.

A Special Note about Young Persons

Young Persons between the ages of 8 and 18 years are eligible to use Soldo Services on the basis set out below. We ask that parents and legal guardians to explain this section to them.

Each parent or legal guardian who signs-up a Young Person to use the Soldo Services is providing their permission for us to collect, use and share the Young Person’s Personal Data in the ways set out in this Privacy Policy.

When a parent or legal guardian provides contact information for a Young Person, they are giving their permission for the Young Person to be contacted.

We encourage parents and legal guardians to explain to Young Persons how their information will be used, as set out in this Privacy Policy.

Protecting the privacy of every user of Soldo Services, including Young Persons, is important to Soldo. We are committed to the following principles:

  • We will send the following communications to Young Persons: essential service communications, for example, relating to an attempted spend at non-permitted merchant, responses to enquiries, Soldo Services usage alerts, for example, their allowance is switched on/off) and Soldo Services updates.
  • Parents or legal guardians may opt-out of marketing messages being sent to a Young Person. To do so please read section “Unsubscribing from services”.

We are reliant on parents and legal guardians to provide accurate information relating to a Young Person. We cannot be held responsible if parents or legal guardians circumvent age-restrictions by providing incorrect age information.

3. Information that we collect

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, Sweepstakes and Profile Data: From time to time, we offer optional questionnaires, surveys and sweepstakes 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, and sweepstakes, 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.

4. How We use the information We collect

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, Sweepstakes, 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, manage the sweepstakes, 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.

We may use your Personal Data to ensure that content is presented in the most effective manner for you and for your device.  We may also use data collected to improve our service, for example to carry out statistical analysis, including data analytics, developing and analysing data metrics, anonymising personal data and publishing the results in an aggregated form. We may also use data for internal management reporting and metrics. To ensure a consistent Soldo experience we will use information collected when you use Soldo Services via our Soldo Client or website using such technologies as cookies and pixel tags. This information may be used to customise any messaging you are presented with. Please see the Section 9 for the Soldo Cookie policy for further information.

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.

By accepting this Privacy Policy, you expressly agree and consent that each time you make a payment transaction with another Soldo user using your Soldo Account, we may transfer the aforementioned relevant data to such Soldo User, in order to process, execute or otherwise deal with the payment transaction.

With Other Third Parties:

Soldo will not sell or rent any of your Personal Data to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy.

5. Information Security

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 passcode protection

  • We have built in 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 Account and Services Terms and Conditions and its Annexes. relating to your Passcode, and Card PIN to ensure on-going security of the Soldo Services.
  • We do not recommend PINs 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.

6. The rules and guidelines we follow
Soldo is registered with the Information Commissioner’s Office and we have developed our internal data protection policies to comply with data protection laws.

7. Keeping your data up to date

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 5 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.

Your rights

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.

General enquiries regarding our privacy policy

If you have any questions about how we use your Personal Data or about this privacy policy please contact the Soldo Customer Care (see “Contact us” page).

8. Unsubscribing from services

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.

9. Cookie Policy

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?

On our website, we may use Cookies to record information about your online preferences and allow us to tailor the website to your interests and needs. Users have the opportunity to set their devices to accept all Cookies, to notify them when a Cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features can’t then be provided to you and consequently you may not be able to use all our website features. Each browser is different, so check the “Help” menu of your browser to learn how to change your Cookie preferences.

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.

Why do we use cookies?

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:

 

Session cookies These are temporary cookies that remain in the cookie file of your browser until you close the browser. They enable information to be maintained across pages of our site to provide you with a better experience.

These cookies can’t personally identify you and they’ll expire when you close down your browser.

Persistent cookies These remain in the cookie file of your browser for much longer (the amount of time will depend on the life time of  each cookie). These cookies help us to recognise you as a unique visitor when you return to our website and to allow us to tailor content or advertisements to match your preferred interests and to avoid showing you the same adverts repeatedly.

Persistent cookies also enable information to be maintained across pages of our website and avoid you having to re-enter information.

Google Analytics

Google Analytics Google Analytics cookies collect and store information on how visitors are interacting with our website. For example, what webpages are visited most often, how long for, and what device you use to visit these pages.

We use these cookies to ensure areas of our website are working correctly and that we are providing users with relevant information. No identifiable information can be stored in or obtained from these cookies.

Learn more about Google Analytics Cookies and Privacy.

Google Ad- Preferences Google sets a cookie on your browser that anonymously captures your interests allowing their advertising partners to present products and services on their websites that are relevant to you. Google are in full control of these cookies.

You can change your Google Ad-Preferences or find out more about Google Ad-Preferences by visiting: www.google.com/ads/preferences/.

Facebook, Twitter These companies set a cookie to deliver relevant ads, track ad campaign performance and efficiency. For example, we may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites.
Adjust, Mixpanel These companies may use a cookie, attribution service or another similar technology to determine whether we’ve served an ad and how it performed or provide us with information about how you interact with them.
Third Party Cookies Authorised Third Parties may use cookies on our website.  These are under our direct control and are used to compile anonymous, aggregated statistics that allow us to understand how visitors use our site and to help us improve the structure of our website. We can’t identify you personally in this way.

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.

10. Accountability

Our Compliance Officer is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy and with UK data protection laws. You have the right to request the Personal Data that we hold about you.  You can also contact us if you have any questions about this Privacy Policy by contacting us by email at support_uk@soldo.com, by calling the Soldo Customer Care number located on our Term & Conditions, or by writing to us at Soldo Financial Services Ltd., BOX 324, 19-21 Crawford Street, W1H 1PJ London, UK.