Effective Date: August 15, 2022
Solo Global, Inc. (“Solo,” “we,” “us,” or “our”) provides services which aim to help solo-prenenurs, freelancers, gig-workers, contractors, sole-proprietors and microbusinesses easily manage their business finances, including services which aim to help our users make payments, receive payments, and withdraw funds. This Privacy Notice is designed to help you understand how we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”
For information on our processing of Non-public Information that is subject to Gramm-Leach-Bliley Act (“GLBA”), please see Annex A – GLBA Privacy Notice.
Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.
2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
- Account Administration. We may collect personal information and other information from you in connection with the administration of your account. This information may include, but is not limited to, your name, email address, phone number, address, date of birth, professional details, information related to your company, including the company’s legal name, address, copies of your company’s corporate documents, and Employer Identification Number (EIN), government issued identification such as passport or driver’s license, Tax Identification Number, Social Security Number, information related to QR codes used in connection with the Services, and any other information you provide or that we collect.
- Financial and Transactional Information. We may collect financial information such as your bank account numbers, bank statements, transaction history, and credit/debit card numbers. We may collect personal information and details associated with the transactions you enter into using the Services including, but not limited to, the party you are transacting with, transaction amount, transaction date, transaction location, the purpose or subject matter of the transaction, information on sources of your funds, sender and receiver of funds, and information provided to us by the card network associated with transactions, merchants, or cardholders.
Please note that any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
- Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or other Solo communications, enroll in our loyalty program, request customer or technical support, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., payment services, profile pages, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
- Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use our Services.
- Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Location Information. We may collect precise location information, such as when you have “Location Services” or another similar feature enabled in our mobile application.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
- Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
See “Your Privacy Choices and Right” below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.
- Biometric Information. If you consent to our collection of biometric information or if our collection of biometric information is otherwise permitted, you agree that we may use facial recognition technology to extract biometric information contained in facial images that you provide to the Services. For example, we may compare the face on your government-issued photo ID against a selfie that you provide to us. We use this biometric information for identity verification and fraud prevention. This information may be shared with our service providers to facilitate these purposes. Where required by law, we will delete your biometric information within three years from your last interaction with the Services.
C. Personal Information Collected from Other Sources
Third-Party Services and Sources. We may obtain personal information about you from other sources, including through Third-Party Services (defined below) and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
Credit Bureaus and ID Verification Partners. We may obtain personal information about you from credit bureaus, consumer reporting agencies and identity verification partners.
Affiliates. Solo may obtain personal information from its corporate affiliates.
Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Third parties may also use the Services to upload personal information about you, including when they tag you. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
3. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Determine eligibility for Solo products or services;
- Facilitating transactions you enter into;
- To enforce our terms;
- To collect on a debt;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading, or enhancing our Services;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Sharing personal information with third parties as needed to provide the Services;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
E. Other Purposes
We also use your personal information for other purposes as requested by you or as permitted by applicable law.
- Automated Decision Making. We may engage in automated decision making, including profiling. For example, we may engage in automated decision making to grant debit balance increases on your debit card. Solo’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
- De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your personal information are described below.
- Third Parties You Transact or Interact With. The Services may allow you to transact or interact with third parties. In order to transact with a third party, you will need to share personal information with the person or company that you are paying or is paying you. Similarly, you may interact with third parties through your profile page or through interactive features offered via the Services.
- Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.
- Consumer Reporting Agencies. We may share personal information about you with consumer reporting agencies if we obtain a consumer report about you in accordance with applicable law.
- Third-Party Services You Share or Interact With. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). For example, you may use the Services to interact with Third-Party Services such as financial institutions and vice versa.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with our corporate affiliates.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
- APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
- All the above categories exclude text messaging originator opt-in data and consent, which information will not be shared with any third parties, except that we may share such data with (1) our service providers who assist us in providing the Services, and who will not use such information for their own purposes; and (2) if the user consents to our sharing of such information.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice.
- Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below
- Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
- Phone Calls. If you receive an unwanted marketing phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
- Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to our processing of your personal information; and
- Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
6. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.
7. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Solo has collected about them, and whether Solo disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:
Category of Personal Information Collected by Solo
Category of Third Parties Personal Information is Disclosed to for a Business Purpose
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Protected classification characteristics under California or federal law
Internet or other electronic network activity
Professional or employment-related information
Inferences drawn from other personal information to create a profile about a consumer
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
Additional Privacy Rights for California Residents
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, [Company] does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.
Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.
11. CHILDREN’S INFORMATION
The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
12. SUPERVISORY AUTHORITY
If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
13. CONTACT US
Company is the controller of the personal information we process under this Privacy Notice.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
Solo Global, Inc.
2810 N Church St #78363
Wilmington, DE 19802-4447
ANNEX A – GRAMM-LEACH-BLILEY ACT (“GLBA”) PRIVACY NOTICE
This GLBA Privacy Notice supplements our Privacy Notice and only applies to our processing of “Non-public Information” that is subject to the GLBA. All “personal information” referred to in this GLBA Privacy Notice is “Non-public Information” under the GLBA.
WHAT DOES SOLO DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Solo chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does Solo share?
Can you limit this sharing?
For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes—
to offer our products and services to you
For joint marketing with other financial companies
For our affiliates’ everyday business purposes—
information about your transactions and experiences
For our affiliates’ everyday business purposes—
information about your creditworthiness
For our affiliates to market to you
For nonaffiliates to market to you
To limit our sharing
Who we are
Who is providing this notice?
Solo Global, Inc.
What we do
How does Solo protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Solo collect my personal information?
We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.