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Privacy Notice

Fintech Solutions Ltd. (we, our, us) respects your privacy and is committed to protecting your personal data. This privacy notice explains how we use and protect the personal data you provide to us. It also explains your privacy rights and protections.

1. Important information and our details

Purpose of this privacy notice

This privacy notice gives you information about how we collect and process personal data you provide to us, including any data you provide via our websites (our Site), when you register with us, use our software or our platform (Platform), use software we resell, receive services or when you provide us with your contact details through day to day business contact.

We also store on our servers information and data you upload to our Platform regarding your customers (Customer Information).

This privacy notice should be read together with any other privacy notice or fair processing notice we may provide when we are collecting or processing personal data about you. This privacy notice supplements any other notices and is not intended to override them.

Our contact details and roles

We are the data controller responsible for your personal data that you provide, and the data processor for Customer Information that you upload using our Platform (and you are the data controller for the Customer Information).

Our full details are:

Name: Fintech Solutions Ltd Company registration number: 515217008 Email address: support@skalecrm.com

If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 9 below), please contact the data privacy manager using the details set out above.

It is important that the personal data we hold about you is accurate and current, so please let us know if your personal data changes at any time.

Customer Information

All Customer Information is yours, and we will not access Customer Information unless you specifically request us to do so in order to provide you with maintenance and support services.

As the data controller for Customer Information, you are responsible for compliance with all aspects of the GDPR in such regard. We will, of course, assist you in providing any information you require in connection with such compliance, the responsibility for such compliance lies ultimately with you.

Customer Information is retained by us only for so long as you are a customer of ours and for a 3 month period thereafter (in case you decide to become a customer of ours again). Once 3 months has passed since you stopped being a customer of ours, the Customer Information is deleted from our servers.

Third-party links

Our Site and/or our Platform may include links to third-party websites, vendor offerings or other applications, plug-ins and/or 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 website, you should read the privacy notice of any website you visit.

2. The data we collect about you

Personal data, or personal information, 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) and for the purposes of this notice, does not include Customer Information which we will only access with your specific consent (see Customer Information above). We may collect, use, store and transfer the following kinds of personal data about you, which we have summarized into categories:

  • • Identity Data includes first name, last name, username, password or similar identifier.
  • • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or our platform.
  • • Profile Data includes your interests, preferences, feedback and survey responses.
  • • Usage Data includes information about how you use our website, products and services.
  • • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The above categories are used as defined terms elsewhere in this privacy notice, in particular section 4. 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). Our business offering is not intended for children and we do not knowingly collect data relating to children.

Personal data required to perform a contract

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 our obligations under our contract with you. In that case, we may have to cancel a product or service. If we do, we will notify you.

3. How your personal data is collected

We use different methods to collect your personal data including directly from you. You may give us your Identity and Contact Data either face to face or by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • • apply for our products or services;
  • • create an account on our website or platform;
  • • subscribe to our service or publications;
  • • request marketing to be sent to you;
  • • meet us at business or networking events; or
  • • give us some feedback.

Automated technologies or interactions. As you interact with our site or our platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • • Where we need to perform our business contractual obligations to your business.
  • • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • • Where we need to comply with a legal or regulatory obligation.

Legitimate Interest(s) means the interest of conducting and managing our business to enable us to give you good services/products and a good and secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Please contact us if you would like

any further guidance

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms regarding our marketing activities: We may use your Identity, Contact, Technical, Usage and Profile Data to decide what we think you may want or need, or what may be of interest to you to use our platform more effectively. You will receive technical and marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by using the unsubscribe link, or by updating your marketing preferences from links within the e-mail or by contacting us at support@skalecrm.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for the purposes of providing technical support.

Change of purpose

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 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, where this is required or permitted by law.

5. Disclosures of your personal data

We will not share your personal data with others, except if you have asked us to do so, or you otherwise provide your express consent.

6. International transfers

Although your personal data is held within EU secure environments, our employees may view your data over secure internet devices outside the European Economic Area to countries such as Israel, Canada and the US. This classifies as an international data transfer. Whenever we transfer your personal data out of the EEA, we ensure that the data is transmitted using secure, encrypted protocols and subject to security processes. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Personal data retention periods are summarized in the table in paragraph 4. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for

research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have Data Subject Rights under data protection laws in relation to your personal data.

You have the right to:

  • • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 1. if you want us to establish the data’s accuracy;
  • 2. where our use of the data is unlawful but you do not want us to erase it;
  • 3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • 4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  •  
  • • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us at support@skalecrm.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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