Last Revised: 16 March 2020
SolarisPay cares about your privacy. For this reason, we collect and use personal data only as it might be needed for us to deliver to you our world-class products, services, websites and mobile applications (collectively, our “Services”). Your personal data includes information such as:
Date of birth
Other data collected that could directly or indirectly identify you.
If at any time you have questions about our practices or any of your rights described below, you may reach our Data Protection Officer (“DPO”) and our dedicated team that supports this office by contacting us at: firstname.lastname@example.org. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.
What information do we collect? We collect information so that we can provide the best possible experience when you utilise our Services. Much of what you likely consider personal data is collected directly from you when you:
· Create an account or purchase any of our Services (ex: billing information, including name, address, credit card number, government identification).
· Request assistance from our award-winning customer support team (ex: phone number).
· Complete contact forms or request newsletters or other information from us (ex: email); or:
· Participate in contests and surveys, apply for a job, or otherwise participate in activities we promote that might require information about you.
However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance. These methods of collection may not be as obvious to you, so we wanted to highlight and explain below a bit more about what these might be (as they vary from time to time) and how they work:
Account related information is collected in association with your use of our Services, such as account number, purchases, to comply with UK legislation on Anti-Money Laundering and prevention of Terrorist Financing. Information collected may also relate customer service requests and notes or details explaining what you asked for and how we responded.
Data about Usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, cookie/device IDs, page load time, server response time, and approximate location information to measure website performance and improve our systems, including optimising DNS resolution, network routing and server configurations. Specifically, interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data is collected.
Supplemented Data may be received about you from other sources, including publicly available databases or third parties from whom we have purchased data, in which case we may combine this data with information we already have about you so that we can update, expand and analyse the accuracy of our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
How we utilise information.
We strongly believe in both minimising the data we collect and limiting its use and purpose to only that (1) for which we have been given permission, (2) as necessary to deliver the Services you purchase or interact with, or (3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:
Delivering, improving, updating and enhancing the Services we provide to you. We collect various information relating to your purchase, use and/or interactions with our Services. We utilise this information to:
Improve and optimise the operation and performance of our Services (again, including our websites and mobile applications)
Diagnose problems with and identify any security risks, errors, or needed enhancements to the Services
Detect and prevent fraud and abuse of our Services and systems
Collecting aggregate statistics about use of the Services
Understand and analyse how you use our Services and what products and services are most relevant to you.
Often, much of the data collected is aggregated or statistical data about how individuals use our Services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.
Sharing with trusted third parties. We may share your personal data with regulators in fulfilment of our legal obligations or with affiliated companies within our group, with third parties with which we have partnered to allow you to integrate their services into our own Services, and with trusted third party service providers as necessary for them to perform services on our behalf, such as:
Processing credit card payments
Conducting contests or surveys
Performing analysis of our Services and customers demographics
Communicating with you, such as by way email or survey delivery
Customer relationship management.
We only share your personal data as necessary for any third party to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).
Communicating with you. We may contact you directly or through a third party service provider regarding products or services you have signed up or purchased from us, such as necessary to deliver transactional or service related communications. We may also contact you with offers for additional services we think you’ll find valuable if you give us consent, or where allowed based upon legitimate interests. You don’t need to provide consent as a condition to purchase our goods or services. These contacts may include:
Text (SMS) messages
Automated phone calls or text messages.
You may also update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Account Settings” page.
If you make use of a service that allows you to import contacts (ex. using email marketing services to send emails on your behalf), we will only use the contacts and any other personal information for the requested service. If you believe that anyone has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com
Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
Targeted advertisements. Targeted ads or interest-based offers may be presented to you based on your activities on our webpages, and other websites, and based on the products you currently own. These offers will display as varying product banners presented to you while browsing. We also partner with third parties to manage our advertising on our webpages and other websites. Our third party partners may use technologies such as cookies to gather information about such activities in order to provide you with advertising based upon your browsing activities and interests, and to measure advertising effectiveness.
The EU-US and Swiss-US Privacy Shield Frameworks.
SPV Solaris Limited has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
How you can access, update or delete your data.
To easily access, view, update, delete or port your personal data (where available), or to update your subscription preferences, please sign into your Account and visit “Account Settings” for additional information and guidance for accessing, updating or deleting data.
If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honoured only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.
If you are unable for any reason to access your Account Settings you may also contact us by one of the methods described in the “Contact Us” section below.
How we secure, store and retain your data.
We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate.
We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
mandated by law, contract or similar obligations applicable to our business operations;
for preserving, resolving, defending or enforcing our legal/contractual rights; or
needed to maintain adequate and accurate business and financial records.
If you have any questions about the security or retention of your personal data, you can contact us at firstname.lastname@example.org.
‘Do Not Track’ notifications.
Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be used by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal data, please contact us.
Data Protection Authority.
If you are a resident of the European Economic Area (EEA) and believe we maintain your personal data subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority or our lead supervisory authority, the UK's Information Commissioner’s Office, as noted below:
Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire SK9 5AF, United Kingdom
Phone: 0303 123 1113
By Mail: Office of the Data Protection Officer, SPV Solaris Limited, 22 Lytton Road, New Barnet EN5 5BY, United Kingdom
By Phone: 0843 289 1322
We will respond to all requests, inquiries or concerns within thirty (30) days.
Revised: 16 March 2020