Privacy Policy

1. Who we are
1.1

Sklo (“us”, “we”, “our”) needs to collect, use and process your personal data for providing our services when you use our website or our mobile apps. We understand that your personal finances concern to your privacy, and accordingly we created this Privacy Policy.

1.2

The Data Controllers for the collection, processing and use of personal data are:

2. The data we collect about you
2.1

Personal data for collection. Personal data means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. This personal data is collected when you use our website or our mobile app:

a) Full name;
b) Email Address;
c) Data regarding financial transactions: your credit, debit card, bank sender, bank recipient, transaction amounts and currency, payment purpose, time and date of transaction, number of connected bank accounts, number and types of created transaction categories, default currency value;
d) Location;
e) Mobile apps usage: including but not exclusively user actions within our website and/or app, time spent within our website and/or app, used language, used interface preferences, features usage etc., the Internet protocol (IP) address used to connect your device to the Internet, the full Uniform Resource Locators (URL) clickstream to, through and from our website or app (including date and time);
f) Information about your marketing and communication preferences;

2.2

Why we collect your data? Your personal data will only be used:

  1. To fulfill your requests for service, such as providing access to your accounts, and transaction history through our website and mobile app;
  2. To provide you with statistical data regarding your own personal finance spending compared with other users in the region;
  3. To improve our services;
  4. To communicate with you regarding our service;
  5. To comply with any applicable legal and/or regulatory requirements including laws outside of your country of residence or to comply with any legal process;
  6. To administer our services and for internal operations;
  7. To provide you with information about other similar goods and services we offer;
  8. To enforce our Terms and Conditions;
  9. As otherwise set forth in this Privacy Policy;

2.3

We process your personal data on a contract basis, and our contract with you is outlined in our Terms and Conditions;

2.4

Children’s informationOur services are directed at adults (18 years and over) and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents Sklo collecting such data. If any information is collected from a child without verification of parental consent, it will be deleted.

3. How do we protect your personal data
3.1

We use a secure server to store your personal data. All information you provide to us is stored on our secure servers. Any transaction information will be encrypted;

3.2

As you will know, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access;

3.3

We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information;

4. Lawful basis for the use of your personal data
4.1

We will only use your personal information on the base of your consent to process your data; or when we have a legal obligation to process your personal data to comply with laws, regulations or court orders; or when it is necessary for our or a third-party legitimate interests and your interests and fundamental rights do not override those interests; or when it is necessary to fulfil our obligations under a contract with you; or when it is necessary to protect the vital interests of yourself or other individuals.

5. Disclosure of your personal data
5.1

We may share your information with selected third parties including:

  1. affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;
  2. advertisers and advertising networks solely to select and serve relevant adverts to you and others;
  3. analytics and search engine providers that assist us in the improvement and optimization of our site;

5.2

We may disclose your personal information to third parties:

  1. To execute any contract, we enter into with them or you;
  2. To execute a duty to disclose or share your personal data in order to comply with any legal obligation;
  3. If you consent, share your details when using our services;

5.3

We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependent on your specific use of our services. These third parties have been carefully selected based on their ability to provide necessary services to our users. They are required to process personal data in a lawful and transparent manner, and we have agreements in place to ensure that they protect personal information to the same standard as we do. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to [email protected].

6. Sharing and storing your personal data
6.1

By submitting your personal data, you agree to transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. Cookies
7.1

We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with the best experience. It also enables us the ability to improve our services, for detailed information on cookies and other technologies we use and the purposes for which we use them see our Cookie Policy.

8. Retention of your personal data
8.1

We understand that data retention is an important aspect of data protection, and we would like to assure our users that we will only retain personal data for as long as necessary to fulfill the purposes for which it was collected.

8.2

Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.

8.3

We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.

10. Changes to our Privacy Policy
10.1

To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the website and update the “Last Updated” date. To stay up to date on any changes, please check back periodically.

10.2

Your use of our services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at [email protected]

11. Contact
11.1

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to our global privacy team at the following email address – [email protected], or you can write to us at the following address: