Privacy Policy

Privacy Policy

Updated and effective as of 31 March 2022

INTRODUCTION

This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) when you use our Early Pay Platform, whether through our website at www.saltare.io or (if available) our app (together, the “Platform“), access our services or otherwise interact with us.

The Platform enables our buyer customers (“Buyers”) to notify their suppliers (“Suppliers”) that their invoices have been approved for payment, and also to make offers to  Suppliers to pay selected invoices before their scheduled due date, which can be in exchange for a small early payment discount for the buyer. Suppliers may wish to accept the early payment discount as opposed to waiting until the contracted payment date of the invoice.

The Platform is for use by legal entities or individuals acting for purposes relating to their trade, business, craft or profession only.  This Privacy Notice is for:

  • The individual users who access or apply to access the Platform on behalf of a Buyer , and also to their directors or owners;
  • The individual users who access or apply to access the Platform on behalf of or as a Supplier, or who receive invoice notifications or offers of early payment on a Supplier’s behalf or as a Supplier;
  • any other users of our website or app.

It is important that you read this Privacy Notice so that you are fully aware of how and why we are using your data.

The Platform is owned and operated by Saltare Technologies Limited, a company registered in England and Wales with company number 13912477 with its registered office at Unit 5-6 Cube M4 Business Park Old Gloucester Road, Hambrook, Bristol, England, BS16 1FX.

Saltare is registered as a data controller with the Information Commissioner’s Office under data protection registration number ZB310307.

CONTACT US

If you have any questions about our Privacy Notice or your information, or wish to exercise any of your rights as described in this Privacy Notice or under data protection laws, you can contact us:

By post at:

Saltare Technologies Limited,
Unit 5-6 Cube M4 Business Park
Old Gloucester Road,
Bristol,
England,
BS16 1FX

By email at: [email protected]

PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

We:

(a)          collect personal information that you voluntarily submit to us, such as your name and business contact details, when completing forms on the Platform, using the Platform and our services, or otherwise interact with us in the course of our business activities;

(b)          if you are a Supplier of  goods or services, we may obtain your business contact details from one of your customers who wishes to send you invoice notifications, or make an offer to pay your invoice before its scheduled due date;

(c)          collect personal information about you from third parties such as Credit Checking Agencies (as defined below), customer due diligence providers, social networks, public databases (where permitted by law), our advertising partners and our other business partners where we carry out joint business activities;

(c)           may also collect certain personal information automatically, including in relation to how you access and use the Platform, technical information regarding the device you use to access the Platform and the way in which you interact with our email messages (such as whether you open these).

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We will indicate to you where the provision of certain personal information is required in order for us to provide certain services to the Business Customer that you represent. If you choose not to provide such personal information, we may not be able to provide the services.

ANONYMOUS DATA

We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Site and developing new products and features. We may also share such anonymised information with others.

WHAT WE DO WITH YOUR PERSONAL INFORMATION

We will only use your personal information if we have a legal basis for doing so. The purposes for which we use and process your information and the legal basis on which we carry out each type of processing is explained below:

  • To perform our agreements with Buyers and Suppliers, our day-to-day business activities and operations. This may include corresponding with you about matters relating to the Platform, including notifications to Buyers and Suppliers regarding invoices that have been selected for early payment, to request feedback on the Platform and to communicate with Buyers about billing matters.

Lawful basis: It is in our legitimate interests to ensure Buyers and Suppliers are provided with the services they have requested from us and that we continually improve these.  It is in our legitimate interests to communicate with Buyers regarding billing to ensure we are paid for our services.

  • To send you information regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and security alerts.

Lawful basis: It is in our legitimate interests to ensure that the Platform functions properly and to resolve issues with it where required, and to ensure that the Platform is secure and operates in accordance with applicable law and regulation. It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you so that you are aware of these.

  • To run credit checks to assess your and/or the Buyer’s creditworthiness and eligibility to use our services based on our internal rules, and where necessary, share this with other financial institutions to comply with relevant laws.

Lawful basis: your consent.

  • To run sanctions screening and customer due diligence checks (including anti money laundering checks) based on our internal rules and/or legal and regulatory requirements.

Lawful basis: Compliance with a legal obligation.  It is also in our legitimate interests to verify the identity of and assess the suitability of customers that may receive our services to prevent criminal activity and to protect us against the risk of customers failing to repay us.

  • To provide and administer the Platform, including resolving technical issues, troubleshooting, data analysis, testing, research, statistical and survey purposes.

Lawful basis: It is in our legitimate interests to ensure that the Platform functions properly and to resolve issues with it where required.

  • To improve the Platform to ensure that content is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Platform.

Lawful basis: Your consent.

  • To anonymise and aggregate the data we collect through the Platform in the course of providing the services to our customers for statistical and research purposes.

Lawful basis: It is in our legitimate interests to anonymise the personal data we collect in the course of providing our services in order that we can carry out research, prepare reports and promote our services.

  • To send communications to you as follows:
    • Saltare will send out marketing messages and notifications generated by the Early Pay platform.
    • Marketing messages are issued by email and only if we have your consent to do so or where we have an alternative lawful basis to do so.
    • Each marketing email and SMS will clearly state that it is from Saltare and will contain a link to our website, which allows you to change the communications you receive (opt-out), or other opt-out method. You can also contact the Marketing Team through the options shown in the “How to contact us” section.
    • The Early Pay platform will only send notifications (either by email, push notifications or SMS text) to users to enable the application to function efficiently.

Lawful basis: Your consent (if required under applicable law). Where consent is not required, such processing is necessary in our legitimate interests to grow and develop our business, and to provide the Platform to Buyers and Suppliers.

  1. CREDIT CHECKS ON BUYERS

[Please read the following information very carefully:

If a Buyer chooses to pay suppliers using a virtual card, we will be under an obligation to take steps to ensure that they are suitable to receive our services.

We use a variety of methods to try to make sure that we do not issue virtual cards to Buyers who are unsuitable to use our services. In order to do this, we share with and receive your personal information from certain credit reference agencies and other third parties who collect, consolidate, and provide us with such personal information.

DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf as required to achieve the purposes described above, which may include providing web hosting or analytics services and may also include the Credit Checking Agencies and customer due diligence service providers.

INTERNATIONAL TRANSFERS

As detailed above, we may share your data with our service providers and some of these may be based outside of the United Kingdom (“UK”) and European Economic Area (“EEA”). This may involve transferring your personal data internationally outside the UK and the EEA.

Where personal information is transferred to and stored in a country not determined by the UK or European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission, obliging recipients to protect your personal information.

If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA, please contact us using the details set out in the Contact Us section above.

SECURITY OF YOUR PERSONAL INFORMATION

We use appropriate technical and organisational security measures (including encryption) to protect personal information from unauthorised use, loss, alteration or destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.

Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Personal information that we process for the purpose of carrying out anti money laundering checks (and ancillary functions related to this) as part of our customer due diligence checks will be retained for 6 years from the date of collection, in line with legal and regulatory requirements.

YOUR RIGHTS

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

  • Right of access. You have the right to obtain access to your personal information.
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to object. You have a right to object to any processing based on our legitimate interests in certain circumstances.
  • Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent but without affecting the lawfulness of processing based on consent before its withdrawal.

Please note that not all of the above rights are absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

You can exercise any of your rights as described in this Privacy Notice and under data protection laws by contacting us as provided in the Contact Us section above.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies and similar technologies on the Platform for various purposes, including improving your experience of the Platform. For more information about cookies and why we use these, please refer to our Cookies Policy [insert link].

COMPLAINTS

If you have any questions or concerns regarding our Privacy Notice or practices, please contact us as provided in the Contacting Us section above. You also have the right to complain to the UK Information Commissioner’s Office (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Notice from time to time. Any changes will be posted on the Platform with an updated revision date. If we make any material changes to this Privacy Notice, we may notify you by email or by means of a prominent notice on the Platform prior to the change becoming effective.

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