Privacy Policy

Privacy Policy

Version 2.0

9 September 2022

1. Introduction

1.1 Important information and who we are

Welcome to GoSolo Financial Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At GoSolo Financial Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is your data controller

GoSolo Financial Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at we@gosolo.net or sent in a letter to 128 City Road, London, EC1V 2NX, United Kingdom.

1.3 Processing data on behalf of a controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach;

1.4 Getting in touch

You can contact us in one of the following ways:

• email us at we@gosolo.net
• WhatsApp us on +44 7483 901626
• Send a letter to:

GoSolo Financial Limited

128 City Road

London, EC1V 2NX

United Kingdom

We'll respond within a month in line with data protection laws.

2. Information we hold about you and how we use it

2.1 Types of data we collect and  Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect and use information about you that is picked up when you interact with us such as through our websites, when you use the Web and/or Mobile App, when you open and use GoSolo account(s), if you get in touch with us, if you apply for a job or if you use a service that integrates with us. We also collect and use information about you that is available in public domain.

Table below shows all the different types of personal information that we may collect, use, store and transfer. We don’t use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.

We also collect use and share Aggregated Data such as average number and amount of the invoices created, average time it takes for an invoice to be paid. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 If you choose not to provide requested information

You don't have to share information about yourself. But if you don't, you may not be able to use some, or any, of our services. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

2.3 The legal basis for collecting personal data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – these cover aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.

We will only use your Personal Data when the law allows us to. Table below contains a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.

2.4 Change of purpose for use of personal data

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. Your rights and how your personal data is protected

3.1 What control do I have over GoSolo Financial Ltd’s use of my personal data?

You have a right to:

• access the personal data we hold about you, or to get a copy of it;
• ask for a copy of your personal data in a portable (machine-readable) format or make us send it to someone else;
• make us correct inaccurate data;
• say no to us using your data for direct marketing and in certain circumstances 'legitimate interests', research and statistical reasons;
• ask us to delete your data (though for legal reasons we might not always be able to do it);
• withdraw any consent you've given us, and;
• lodge a complaint about how we use your personal information.

To do any of these things, please get in touch using the details in “Getting in touch” section.

3.1.1 How can I request for a copy of my personal data?

Most of the time, you can access what you need without writing to us to ask for it. You can easily view most of the information we hold about you through GoSolo web or mobile app.

If you want to know something specific or have been unable to find the answer to your question, you may want to make a Data Subject Access Request instead. You can do so by contacting us at we@gosolo.net indicating “Data Subject Access Request” or “DSAR” in the email subject line and indicating the type of information you are looking for. Please note that we may be required to verify your identity prior to processing your request - this is to ensure that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request.

Please note that DSAR can be refused if it is manifestly unfounded or excessive.

3.1.2 How do I update my personal information if it’s incorrect?

If you wish to update information about you which is inaccurate or incorrect, you can do so by contacting us (see section Getting in touch). Please note that we may need to verify your identity and verify your updated information before it can be updated.

3.1.3 How do I opt out of marketing communications?

You can ask us to stop sending you marketing messages at any time by writing to we@gosolo.net.

When you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

Please note that if you update your permissions on direct marketing, there may be a period of time before the update takes effect and you may be sent direct marketing during this time.

3.1.4 How do I delete my data?

You may request that we delete your personal and account information. Please note that we may not be able to process your request if one of the following conditions apply:

• we need to retain your information for any of the matters set out in the section “The legal basis for collecting personal data”;
• your information may be impossible to permanently delete and where this is not possible we will put that information beyond reasonable use;
• your information which you have shared with others (e.g. on our websites) may remain publicly available;
• please note that your information which you have transmitted to others, e.g. Marketplace partners, will be subject to the privacy policies of those others.

To delete your data, please contact us though for legal reasons we might not always be able to do it.

3.1.5 How do I withdraw my consent to use my personal information?

You can ask us to stop using all or some of your information, withdraw consent or to limit our use of it by contacting us. This will only affect the way we use information when our reason for doing so is that we have your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Please note that we may not be able to process your request If we are required to retain or use your personal data for the purposes described in section “The legal basis for collecting personal data” other than your consent.

Your information that you have sent to others (e.g. Marketplace partners) will be subject to the privacy policy of those others.

3.1.6 How do I complain?

If you have a complaint about how we use your personal information, please contact us at we@gosolo.net and we’ll do our best to fix the problem.

If you’re still not happy, you can refer your complaint to the ICO’s Office, the UK regulator for data protection issues. For more details, see www.ico.org.uk

3.2 How does GoSolo Financial Ltd protect customers' personal data?

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

We make every effort to keep your data secure and protect it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of GoSolo Financial Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4. Who we share your data with

4.1 Organisations we share your data with

We may share your information with our affiliates, with those we do business with, with credit reference and fraud prevention agencies, with law enforcement bodies and regulators or if the information is aggregated (and so cannot identify you specifically). We share as little information as we can and encrypt and/or make it impossible for the recipient to identify you where possible (for example, by using a User ID rather than your name).

Here is a list of organisations we may share your data with:

• Card producers and networks, e.g. Mastercard,
• Card processing partners,
• Know Your Customer (KYC) and cyber security service providers that help us with identity verification or fraud checks,
• Cloud computing power, storage and software providers,
• Our business intelligence and analytics platform provider,
• Companies that help us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time),
• Software companies that we use to email you, or for processing and storing emails with you,
• Software companies that we use to send SMS to you,
• Companies that help us with customer support,
• Companies that help us with fraud prevention,
• Companies that offer benefits or rewards through special programmes you sign up to in the app,
• Company registrar e.g. Companies House if you are registering a new company,
• Virtual business address provider if you apply for this service,
• Anyone you give us permission to share it with.

If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply any agreement with you or our suppliers, to protect the rights, property or safety of GoSolo, our customers or others. This includes:

• Law enforcement agencies, courts or dispute resolution bodies,
• Authorities that spot and stop financial crime, money laundering, terrorism and tax evasion,
• Tax authorities,
• Other banks to help trace money if you are a victim of fraud or other crimes, or if there’s a dispute about a payment,
• Any other third parties where necessary to meet with our legal or contractual obligations.

4.2 Our key partner as Data Controller

In addition to the above, GoSolo also shares this data with our key partner PayrNet Limited. GoSolo Financial Limited is listed with the Financial Conduct Authority as an EMD Agent under E-Money Institution PayrNet Limited, who plays an integral role in allowing us to offer our products and services to our customers. Generally speaking, PayrNet holds and processes your personal data for the same reasons and in similar ways to GoSolo.

PayrNet is also a Data Controller in relation to your personal data shared with them. This means that if you would like to exercise any of the rights afforded to you by the personal data protection laws applicable to your case, PayrNet must be contacted separately from GoSolo.

PayrNet does not use your personal data for marketing purposes and will not share your personal data with third parties for marketing purposes.

PayrNet Privacy Policy can be found here: https://www.railsr.com/payrnet

You can contact PayrNet with regards to your privacy queries at support@railsbank.com.

4.3 Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

5. How long will we retain your data for?

This section explains how long we may keep your information for and why.

We will keep your personal information for as long as you are using GoSolo. After you close your account with GoSolo, we will continue to keep your personal and account information for 6 years after that so that we:

• comply with the Anti Money Laundering Regulations,
• comply with the law if we face a legal challenge,
• can respond to a question or complaint,
• can show whether we gave you fair treatment.

We may also keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. As an example, we may be required to continue to keep your data in case of court proceedings.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We will only use your personal information for those purposes and will make sure that your privacy is protected.

6. Age limit for our users

You must not use GoSolo Financial Ltd unless you are aged 18 or older. If you are under 18 and you access GoSolo Financial Ltd by lying about your age, you must immediately stop using GoSolo Financial Ltd.

This website is not intended for children and we do not knowingly collect data relating to children.

7. Where do we process or store your information or transfer it

We process and store your information on the servers located in the UK and EEA. We may only send your data outside of the European Economic Area (‘EEA’) to:

• Follow your instructions;
• Comply with a legal duty;
• Work with our suppliers who help us to run your accounts and services.

If we do transfer your personal information outside the UK and EEA to our suppliers, we will make sure that it is protected to the same extent as in the UK and EEA. We’ll use one of these safeguards:

• the Information Commissioner (ICO) has deemed the country or organisation to provide an adequate level of protection for personal data;
• we've agreed specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

8. Notification of changes and acceptance of policy

We keep our Privacy Policy under constant review and will place any updates on this webpage. When we make updates to GoSolo Privacy Policy, you will be notified of the changes made to the Policy via email. By using GoSolo Financial Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of GoSolo Financial Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

9. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of GoSolo Financial Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a GoSolo Financial Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any GoSolo Financial Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the GoSolo Financial Ltd legal department.