Privacy & Data Protection Policy

Introduction

Satago Financial Solutions Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit or use www.satago.com and app.satago.com (together the "Site") and when you use the services, features, content or applications we offer (collectively with the Site, the "Services"). It will also tell you about your privacy rights and how the law protects you.

Satago is a technology and data platform. As well as our own credit control and risk insights tools, we help you access invoice finance and related products provided by third-party lenders. We do not provide invoice finance ourselves; the lender provides the finance and makes the lending decision.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important information and who we are

This privacy policy aims to give you information on how Satago Financial Solutions Limited collects and processes your personal data through your use of the Services, including any data you may provide (i) when you register for the Site and the Services, through your user account and (ii) your use of the Services generally.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy supplements any other notices and privacy policies we may provide on specific occasions when we are collecting or processing personal data about you and is not intended to override them.

2.1 Satago

Satago Financial Solutions Limited is the controller and responsible for your personal data (collectively referred to as "Satago", "we", "us" or "our" in this privacy policy), as set out in this privacy policy. We are registered in England and Wales under company number 09998904, and have our registered office at 88 Kingsway London, WC2B 6AA. We are registered with the Information Commissioner's Office under registration number ZA648043.

Please note that where we provide Services to you, Satago is the processor, and you are the controller, of any third-party personal data you provide to us (such as your customers' name, contact details and their accounts and receivables information) to enable us to provide certain features the Services ("Third-Party Data"). The data processing provisions governing our use of such personal data are contained in our software terms and conditions with you. You must not input, upload, provide or otherwise make available to or through the Services any Third-Party Data unless you have a legal right to do so.

Where you use our platform to access invoice finance, the lender, and not Satago, provides the finance and is responsible for the lending decision and for the customer due diligence and anti-money-laundering checks required by law. Depending on the service, we act either as a controller (for example when we introduce you to a lender) or as a lender's processor (for example when we provide technology or an account data feed to a lender on its instructions). The 'How we work with lenders' section below explains this in more detail.

2.2 Contact details

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: legal@satago.com

Postal address: Data Protection Officer, Satago Financial Solutions, 88 Kingsway London, WC2B 6AA

If you are unhappy with how we have handled your personal data, you have the right to complain to us. You can do so using the contact details above. We will acknowledge your complaint within thirty days and respond to it without undue delay.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO, now the Information Commission), the UK supervisory authority for data protection issues (https://ico.org.uk). We would, however, appreciate the chance to deal with your concerns first, so please contact us in the first instance.

2.3 Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [date of publication].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.4 Third-party links

Our Site may include links to third-party websites, plug-ins and 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 Site, we encourage you to read the privacy policy of every website you visit.

2.5 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title, date of birth and username.

Contact Data includes business address, home address, email address and telephone numbers.

Financial Data includes bank account details and information relating to your accounts and receivables. We do not hold payment card numbers or card security codes; payment details are provided directly to our payment provider. For further information on this refer to the 'Financial Data' section of 'How we use your personal data'.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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 the Services.

Profile Data includes your username and password, purchases or orders made by you, your preferences and survey responses.

Usage Data includes information about how you use our Site, products and services.

Third Party User Data includes email message bodies (including attachments), metadata, headers, and settings when using our email integration services, and the content of messages sent from, and received at, an email address we operate on your behalf. For further information on this see the 'Additional restrictions on the use of Third Party User Data' section of 'How we use your personal data'. Of the connected mailbox integrations, full message-content access applies only to the Microsoft / Outlook integration; for Gmail we use send-only access, as described in the 'Use of Google APIs and Gmail Data' addendum below. We also receive replies sent to an email address we operate on your behalf.

Connected Service Data includes account identifiers (such as an email address) collected when you authorise a third-party service (such as a Google Workspace account) to integrate with the Satago platform via an authorised integration provider. For further information on this, refer to the 'Use of Google APIs and Gmail Data' addendum below.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not seek to 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), and we do not ask you for it. Because the email features handle messages written by you and by the people you correspond with, information of this kind may occasionally appear in the content of a message. Where it does, we process it only as part of the message, on your instructions, and we do not use it for our own purposes or to infer anything about anyone. We do not alter or delete your correspondence except on your instructions, to comply with a valid request under your rights, or where the law requires it. Where you apply for invoice finance through our platform, the lender carries out the customer due diligence, sanctions and anti-money-laundering checks required by law as a controller in its own right, and any criminal-offence data involved in that screening is processed by the lender and not by us. We do not carry out those checks on new applicants.

Two things follow from our previous role. We hold customer due diligence and screening records from the period when we provided invoice finance ourselves, and we keep them for the periods described in section 8, which are longer than the minimum the money laundering rules require. While we continue to operate client trust accounts, we also monitor transactions on those accounts for unusual activity, as we are required to do in order to prevent money laundering. Information of this kind may also arise where we investigate suspected fraudulent use of the Services, for example where one of your customers replies to say that it does not recognise an invoice raised against it. Where information about criminal convictions, offences or related allegations arises in any of these ways, we process it only where a condition under the Data Protection Act 2018 is met, in particular the prevention or detection of unlawful acts. That condition applies in addition to a lawful basis under Article 6, which is set out in section 4.1, and not instead of it. We maintain an appropriate policy document as that Act requires.

2.6 If you fail to provide personal data

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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1 Direct interactions

You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

register to use our Site;

subscribe to our Services;

participate in discussion boards or other social media functions on our Site;

request marketing to be sent to you;

enter a competition, promotion or survey; or

give us feedback or contact us.

3.2 Automated technologies or interactions

As you interact with our Site, we will 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. Please see our cookie policy for further details.

3.3 Third parties or publicly available sources

We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from analytics providers, including Google Analytics (further information can be found here: How Google uses information from sites or apps that use our services – Privacy & Terms – Google)

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our Payment Processors including Stripe;

Identity and Contact Data from providers of business information such as Creditsafe Business Solutions Limited and RSM Tracker. This is publicly available information, including company contact details and the names of directors and officers as recorded at Companies House;

Identity Data, and information generated by identity verification and financial crime screening, from SmartCredit Ltd, where such checks are carried out. In carrying out those checks SmartCredit draws on sources of its own, including the Electoral Register. We do not search the Electoral Register ourselves;

Identity and Contact Data from publicly available sources such as Companies House;

Third Party User Data from Microsoft, including Office365/Outlook, and from messages sent to an email address we operate on your behalf. The Gmail integration is send-only and does not provide us with message content; Google and Nylas provide account identifiers, which are Connected Service Data

Connected Service Data from third-party authentication and integration providers (such as Nylas) when you authorise a connected service via OAuth

Financial Data from Open Banking connections provided by Tink, our regulated account information service provider, where you choose to connect a bank account so that the lender to which your application has been allocated can assess or service your finance facility.

4.0 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 the contract we are about to enter into or have entered into with you.

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 obligation.

Refer to 'Lawful Basis' to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message, and before introducing you to a third-party lender and sharing your personal data with them. You have the right to withdraw consent at any time by contacting us. Withdrawing your consent to an introduction stops us making further disclosures to that lender on the basis of your consent. It does not affect processing already carried out, processing the lender carries out under its own legal obligations or its agreement with you, or processing we carry out on that lender's instructions once it is servicing your facility, which is governed by our agreement with the lender.

4.1 Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

The lawful bases below are the bases we rely on where we act as a controller. Where we process data on the instructions of someone else, as we do with the Third-Party Data you provide to us and with data we handle for a lender, that person is the controller and decides the lawful basis for it; we act on their documented instructions.

Purpose/Activity: To register you as a new user Type of data: (a) Identity; (b) Contact Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

Purpose/Activity: To provide the Services to you including: (a) Allowing you to participate in interactive features of the Services (b) Providing email integration services Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications; (f) Third Party User Data Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests

Purpose/Activity: To send communications initiated by you through the platform, including via connected third-party email services (such as Gmail via Nylas) or from an email address we operate on your behalf, and, where the route permits, to receive and record replies to them Type of data: (a) Identity; (b) Contact; (c) Connected Service Data; (d) Third Party User Data Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (providing the service you have requested)

Purpose/Activity: To introduce you to a third-party lender, where you ask us to do so, and to share your information with that lender so that it can assess and, if appropriate, provide a facility to you Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction Lawful basis for processing including basis of legitimate interest: (a) Your consent; (b) Necessary for our legitimate interests (operating our platform and making introductions)

Purpose/Activity: To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Notifying you about changes to our Services. (c) Asking you to leave a review or take a survey Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose/Activity: To administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Type of data: (a) Identity; (b) Contact; (c) Technical Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant Site content to you in the most effective manner for you and your computer Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Type of data: (a) Technical; (b) Usage Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you Type of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and Communications Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose/Activity: To monitor transactions on the client trust accounts we operate, in order to identify unusual activity and prevent money laundering Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction Lawful basis for processing including basis of legitimate interest: Necessary to comply with a legal obligation. Where information about criminal convictions, offences or related allegations arises, we also meet a condition in Schedule 1 to the Data Protection Act 2018, in particular the prevention or detection of unlawful acts. That condition applies in addition to this lawful basis, not instead of it

Purpose/Activity: To retain the customer due diligence and screening records we created during the period when we provided invoice finance ourselves Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction Lawful basis for processing including basis of legitimate interest: (a) Necessary to comply with a legal obligation, for the period the money laundering rules require; and (b) after that period, necessary for our legitimate interests (keeping records that may be needed to establish, exercise or defend a legal claim). Where those records contain information about criminal convictions, offences or related allegations, we also meet a Schedule 1 condition as described above

Purpose/Activity: To detect, investigate and prevent fraudulent use of the Services, including where one of your customers tells us that it does not recognise an invoice raised against it Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Third Party User Data Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (preventing and detecting fraud against us, our customers, the lenders we work with and their customers); and (b) where it applies, necessary to comply with a legal obligation. Where this involves information about criminal convictions, offences or related allegations, we also meet a Schedule 1 condition as described above

Purpose/Activity: To comply with our other legal obligations, including tax, accounting and regulatory reporting requirements Type of data: (a) Identity; (b) Contact; (c) Transaction Lawful basis for processing including basis of legitimate interest: To comply with a legal obligation

Automated decision-making

We do not make decisions about you based solely on automated processing of your personal data.

Our Risk Insights tools produce credit scores, risk bands and suggested credit limits. These relate to businesses and other legal entities, and not to individuals. No personal data is used in producing them: they are generated from accounting data and from business information about companies. We do not produce credit scores, risk bands or suggested credit limits in respect of sole traders or partnerships.

Where you apply for invoice finance through our platform, the lender assesses your application and makes the lending decision. Any assessment carried out by a lender is subject to that lender's own privacy terms.

4.2 Additional restrictions on the use of third party user data

Notwithstanding anything else in this Privacy Policy, if you provide us with access to Third Party User Data, then the use of that data will be subject to these additional restrictions:

Use: We will only use access to read, write, modify, or control email message bodies (including attachments), metadata, headers, and settings (Third Party User Data) to send credit control communications on your behalf and, where the integration allows it, to receive and display replies to them. The access available to us depends on the route: for a Microsoft or Outlook mailbox, and for an address we operate, we handle message content and replies; for Gmail we can only send, as set out in the 'Use of Google APIs and Gmail Data' addendum.

Transfer: We will not transfer Third Party User Data to any third party unless doing so is:

necessary to provide and improve email integration features,

to comply with applicable laws, or

as part of a reorganisation, restructuring, merger, acquisition, or sale of our assets.

Advertising: We will not use Third Party User Data for marketing or advertising purposes and we will not share Third Party User Data with any third party for marketing or advertising purposes.

Human Interaction: We will not allow humans to read Third Party User Data unless:

we have your specific prior consent to humans reading specific messages (for example for tech support),

doing so is necessary for security purposes such as investigating abuse,

to comply with applicable laws, or

for our internal operations and even then only when the Third Party User Data have been aggregated and anonymised.

How your messages are sent. Credit control messages can be sent in two ways. You can connect your own mailbox, in which case messages are sent from your address. What we can see in that mailbox depends on the provider: for a Microsoft or Outlook mailbox we have access to the content of replies, and for a Gmail mailbox we can only send, with no access to your inbox or to replies, as set out in section 2.5 and in the 'Use of Google APIs and Gmail Data' addendum. Alternatively, messages can be sent from an email address that we operate on your behalf. Where we do that, replies are delivered to that address, and we receive and record them so that we can show them to you alongside the relevant invoice. In both cases the messages are yours: we handle them on your instructions and the restrictions in this section apply.

Further to the above, we will adhere to Google's Limited Use Requirements for any information received from Gmail APIs.

Financial Data

All payments for the Services are made through third party payment processing companies ("Payment Processor") and we do not generally store any payment information. We do not receive or store payment card numbers or card security codes. The use and storage of such payment information is governed by the applicable Payment Processor's terms of service and privacy policy. However, sometimes the Payment Processor may provide us with your Financial Data for the purposes of Satago completing transactions for the Services, enrolling you in discount or rebate programs on your request or protecting against fraudulent transactions. Our Payment Processor is Stripe Payments Europe, Limited. Stripe processes some information as our processor, to service its platform and to provide its products and services to us. For much of what it does, however, Stripe acts as an independent controller and determines the purposes and means itself, including selecting the banks and payment method providers used, detecting and preventing fraudulent transactions, managing financial loss and security risks, meeting its anti-money laundering and know-your-customer obligations, and analysing and improving its own products and services. Stripe does this under its own privacy notice, and we do not control that processing.

As many of the Services we offer involve receivables and accounts services, we may, as a result of your use of the Services, obtain from you financial information including information relating to your accounts, receivables, payables, accounting ledgers and accounting reports. We shall use such information solely in furtherance of the Services we provide to you and in accordance with this Privacy Policy.

How we work with lenders

We are a technology and data platform. We help you access invoice finance and related products provided by third-party lenders. We do not provide invoice finance ourselves, and the lender, and not Satago, is responsible for deciding whether to lend, for its lending terms, and for the customer due diligence and anti-money-laundering checks required by law.

Introductions. Where we present and introduce you to a lender through our platform, we and the lender each act as independent controllers of your personal data: we for operating the platform and making the introduction, and the lender for assessing, providing and servicing the facility under its own privacy notice. The information shared may include details about the company and its directors and key parties, such as their name, date of birth, address and contact details and financial information. We may receive a fee from the lender for the introduction, and we work with more than one lender; we present lenders impartially and on objective criteria.

Technology and data services. Where a lender uses our technology, or where we provide a lender with account or accounting data to assess or service your facility, we act as that lender's data processor. We handle the data on the lender's documented instructions and for no purpose of our own.

Some lenders manage your facility through a servicing portal that we host and operate. Where that is the case, the lender's own staff access your accounting, invoice and receivables information, including contact details for your customers, through systems we provide. The lender may also extract reports from the portal into its own systems, and it holds that information itself once it has done so, under its own privacy notice.

Credit reference and business information agencies. We and the lenders we work with may search and share information with credit reference, business information and fraud prevention agencies. These agencies act as independent controllers, keep a record of our searches, and use the data for their own purposes under their own privacy notices.

The business credit information we make available through the Platform concerns companies and other legal entities and does not include information about individuals. Separately, we obtain publicly available business register information, including the names of directors and officers, from Creditsafe Business Solutions Limited and RSM Tracker, and identity verification and financial crime screening from SmartCredit Ltd where such checks are carried out.

Open Banking

Where you choose to connect a bank account, the connection is provided by Tink, our regulated account information service provider, under your explicit consent, and is used only for the service you have asked for.

We operate that connection on behalf of the lender that is assessing or servicing your facility. We handle the bank data on that lender's instructions and do not use it for our own purposes. The connection is offered only once your application has been allocated to a lender, and that lender instructs the request. It is also used while you have an active facility with a lender so that the lender can continue to service it.

You can disconnect at any time, and the connection must be periodically re-authenticated. Tink processes your bank data as described in its own privacy notice, which is shown to you when you connect.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us where we obtained your details in the course of a sale, or of negotiations for a sale, of our services to you, where the marketing relates to our own similar services, and where you did not opt out when we collected your details and have not opted out since. Every marketing message we send gives you a simple way to opt out.

You may also receive marketing communications from us if you have affirmatively opted in to receive them, or where the subscriber to the email address is a corporate subscriber (such as a limited company, a limited liability partnership in England, Wales and Northern Ireland or any partnership in Scotland, a school, a government department or agency, a hospital trust or another public body). Where we market to a business contact on that basis we rely on our legitimate interests in promoting our services, and you can object at any time.

Profiling

To decide what may be relevant to you, we analyse the information described above to predict your likely interests and needs. This is profiling. We use it only for marketing and to improve the Services, never to make a decision about you that produces a legal or similarly significant effect. You can object to profiling for direct marketing at any time, and if you do we will stop.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by logging into your account and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not prevent us using your personal data to contact you other than for marketing purposes (e.g. where we need to contact you in connection with your use of the Services).

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

This applies to third parties who act as our processors. Some recipients described in this policy, including lender partners to whom we introduce you, credit reference and fraud prevention agencies, and our payment provider, act as independent controllers in their own right and use your personal data for their own purposes under their own privacy notices. We do not control that processing. Separately, where we provide technology or data services to a lender, we act as that lender's processor and handle the data on the lender's instructions.

International transfers

We host the Services on cloud infrastructure located in Ireland, within the European Economic Area, and we are established in the United Kingdom. Personal data is therefore processed in both. Transfers from the UK to the EEA are covered by the UK's adequacy regulations, and transfers from Ireland to the UK are covered by the European Commission's adequacy decision for the UK, so no additional safeguard is required in either direction.

Many of our external third parties are based outside the UK, so their processing of your personal data will involve a transfer outside the UK. Whenever we make such a transfer, we ensure a similar degree of protection by relying on at least one of the following:

the country is covered by UK adequacy regulations; or

the UK International Data Transfer Agreement (IDTA), or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, each issued by the Information Commissioner.

Where a transfer is made out of the European Economic Area rather than out of the UK, the EU Standard Contractual Clauses apply instead. Where we rely on the IDTA, the UK Addendum or the EU SCCs, we carry out the applicable transfer risk assessment or data protection test, and we work with our overseas providers to identify any risks to your data. Those assessments do not apply where a transfer relies on adequacy.

Where we transfer personal data from the United Kingdom to the United States in connection with the services we make available to Sage 50 customers in the United States, we rely on the UK Extension to the EU–US Data Privacy Framework where the recipient is certified under it, and otherwise on the mechanisms above. If a mechanism ceases to be available, we will put an alternative safeguard in place. Our partners and any recipients acting as independent controllers are responsible for their own transfer arrangements. See the United States Privacy Addendum below.

Please contact us if you want further information on the specific mechanism used when transferring your personal data out of the UK, including copies of any related documents.

Data security

Your account information will be protected by a password for your privacy and security. To help prevent unauthorised access to your account, you should select and protect your password appropriately and limit access to your computer and browser by signing out after you have finished accessing your account.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

Data retention

We will only retain your personal data 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 data 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.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

By way of indication, we generally retain account and Services data for seven years from the end of your subscription, to meet legal, tax and accounting requirements and to cover the period in which a claim could be brought. Records relating to invoice finance we provided ourselves, including customer due diligence documentation, are retained for seven years from the end of your subscription, or, where we did not go on to provide finance, for seven years from the end of our business relationship with you.

Records of our dealings with you, such as support queries and correspondence, are retained for seven years from our last contact with you, and complaint records for seven years from settlement or closure. Marketing database records are retained for two years from last contact, and evidence of your consent to marketing for six years after that consent is withdrawn or ceases to be valid. Where you opt out of marketing, we keep a record of the opt-out for as long as we need it in order to honour it. Website analytics data is retained for two years.

Data we hold on a lender's instructions, including bank account information obtained through Open Banking for that lender, is retained for as long as that lender's contract with us requires, and is deleted or returned on termination. Bank account information from the period when we provided invoice finance ourselves is retained for seven years, in line with the periods above. Where you connect a mailbox to the service, the tokens, provider identifiers and integration settings that link that mailbox to your account are deleted when you disconnect it or close your account, subject to our ordinary backup cycle. Your email address held as part of your account record is retained under the periods above.

A more detailed retention schedule is available on request.

In some circumstances you can ask us to delete your data: see your legal rights for further information.

In some circumstances we will anonymise 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary to find out more about these rights:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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, or refuse to act on your request, where the request is manifestly unfounded or excessive, in particular because it is repetitive. If we do either, we must be able to show why the request meets that test, and we will explain our reasons and tell you how to challenge the decision.

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 could 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. Where we need further information to confirm your identity or to locate the data, the one-month period will not begin, or will be paused, until we have received it.

10. Glossary

10.1 Lawful basis

10.1.1 Legitimate Interest

This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience, or the similar legitimate interests of a third party. We make sure 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 or those of any third party. We do not use your personal data for activities where those legitimate interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

10.1.2 Performance of Contract

This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

10.1.3 Comply with a legal obligation

This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

10.1.4 Consent

This means processing your personal data where you have given us clear and specific permission to do so for a particular purpose, such as introducing you to a third-party lender. You can withdraw your consent at any time.

10.2 Third parties

10.2.1 Internal Third Parties

Other companies in the Satago Group who may provide you with access to elements of the Services. Satago SPV1 Limited and Satago SPV2 Limited currently hold the client trust bank accounts used in connection with invoice finance. That arrangement is transitional, and those accounts are expected to transfer to the relevant lender.

10.2.2 External Third Parties

Payment providers who process payments for the Services. Our payment provider acts as our processor for part of what it does, and as an independent controller for much of the rest, including fraud prevention and its own anti-money laundering and know-your-customer obligations, under its own privacy notice. See the 'Financial Data' section above.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

Analytics and search engine providers who assist us in the improvement and optimisation of our Site.

API integration and communications service providers that process data on our behalf under contractual confidentiality and data protection obligations (such as authorised email integration platforms).

If you apply for invoice finance through our platform: credit reference agencies and fraud prevention agencies who provide information on your company's credit behaviour, and the lender partners to whom we introduce you. Further information on this is set out in the 'How we work with lenders' section above.

10.3 Your legal rights

You have the right to:

10.3.1 Request access

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.

10.3.2 Request correction

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.

10.3.3 Request erasure

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.

10.3.4 Object to processing

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, including any profiling related to that direct marketing, and we will always stop when you do. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

10.3.5 Request restriction

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:

If you want us to establish the data's accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

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.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.3.6 Request the transfer

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.

10.3.7 Withdraw consent

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.

Addendum: Use of Google APIs and Gmail Data

A. Scope of Integration

Satago integrates with Google Workspace (Gmail) using the Nylas platform to enable authorised users to send emails from their Gmail account within the Satago application.

Nylas acts as Satago's authorised processor and manages authentication and Google API interactions on our behalf.

Satago does not directly access Google APIs.

B. Data Accessed

The integration may access the following Google user data:

Email address of the authenticated user

Basic account metadata required to identify the user (via the user.read scope)

Email send capability via the gmail.send scope

Satago does not access, read, store, or process:

Gmail inboxes

Email message content

Attachments

Labels or threads

C. Data Usage

Google user data is used solely to:

Authenticate users via Google OAuth through Nylas

Send user-initiated emails from the user's Gmail account

Associate the Google account with the relevant Satago user account

Data is not used for advertising, analytics, profiling, or model training.

D. Data Sharing

Google user data is shared only with:

Nylas, Inc., acting as a data processor for authentication and email sending

Google user data is never sold or shared for marketing purposes.

E. Data Storage & Protection

Satago stores only the user's email address

OAuth tokens and credentials are securely handled by Nylas

No Gmail content is stored by Satago

All data is protected using industry-standard security controls including encryption in transit and at rest, access controls, and least-privilege principles.

F. Data Retention & Deletion

The user's email address is retained only for as long as the user maintains an active Satago account or connected integration

Users may disconnect their Google account at any time, immediately revoking access via Nylas

Upon account closure or verified deletion request, all associated Google user data held by Satago is securely deleted in accordance with our data retention and deletion procedures

Users may request deletion of their personal data by contacting Satago using the details provided in this policy.

G. Compliance Statement

Satago's use of Google user data complies with:

Google API Services User Data Policy

Google APIs Terms of Service

UK GDPR and Data Protection Act 2018

We access only the minimum data required to deliver the service and do not retain or use Google user data beyond its stated purpose.

Addendum: United States Privacy Addendum

Scope. This Addendum applies to personal information of United States residents that Satago processes in connection with the Satago application made available to Sage 50 customers in the United States through Sage Software, Inc. Where it conflicts with the rest of this policy, this Addendum governs for those individuals. "Personal information", "business", "service provider", "sell", "share", "business purpose" and "sensitive personal information" have the meanings given in the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (the "CCPA"), and equivalent terms under other applicable US state privacy laws.

What we provide in the United States. In the United States we provide credit control, risk insights and related services. We do not provide invoice finance in the United States. We do not introduce you to lenders, we do not share your information with funding partners, and we do not offer Open Banking bank account connections. We do not offer our embedded accounting functionality in the United States. The sections of this policy headed 'How we work with lenders' and 'Open Banking', and the Embedded Accounting Services (Sage) Addendum, do not apply to you.

Some other parts of this policy describe United Kingdom arrangements that do not apply in the United States. The credit reference, business data and identity verification and screening providers named in section 3.3 are our United Kingdom providers; in the United States we obtain business credit information from a United States provider, and we do not carry out identity verification or financial crime screening ourselves. The Open Banking source described in section 3.3 is not used in the United States. The reference in section 10.2.1 to the client trust bank accounts held by Satago SPV1 Limited and Satago SPV2 Limited concerns a United Kingdom arrangement and does not apply to you. More generally, any other provision of this policy relating to invoice finance, lender introductions, funding partners, Open Banking, embedded accounting, or identity verification and financial crime screening carried out by us or by our United Kingdom screening providers, does not apply to the United States services. This does not affect the processing our payment provider carries out for its own regulatory purposes, which is described below.

Who "you" means in this Addendum. The Satago application is provided to a business. Depending on the context, "you" means either that customer organisation or an individual using the application on its behalf. Where the distinction matters, this Addendum refers to the customer organisation.

Our role for business data. For the accounting, customer, invoice and receivables information entered into, or connected to, the Satago application, we process that information on the customer organisation's behalf and on its instructions. To the extent the CCPA applies and that organisation is a business as defined in it, the organisation is the business and Satago is its service provider. Where another US state privacy law applies and uses the terms controller and processor, the organisation is the controller and Satago the processor. We process that information only to provide the services to you, on your instructions, and for no purpose of our own. The governing terms are our software terms and conditions with you, including the United States addendum to them.

Our role for our own relationship with you. For your account and user registration, your use of the service, our support and our communications with you, and for the business credit information we make available, we decide how and why that information is used.

Sage's role. Sage provides the accounting software and the connector that transmits your subscription and accounting data to us. Sage and Satago each act as independent controllers of the information each receives from the other. Neither of us acts as the other's service provider, and we are not joint controllers. Sage processes your information under its own privacy notice.

Business credit information and the Fair Credit Reporting Act. The credit information we make available through the service is business information. It concerns companies and other legal entities, their creditworthiness, payment performance and risk. We do not provide credit information relating to a consumer, any natural person, an unincorporated association or a sole proprietor. The information we supply is not a "consumer report" for the purposes of the Fair Credit Reporting Act ("FCRA"), and Satago does not act as a consumer reporting agency or as a reseller of consumer reports. You must not use the service, or any information obtained through it, for any purpose regulated by the FCRA, including to establish an individual's eligibility for credit, insurance, employment or housing.

Debt collection. Our credit control features help you communicate with your own business customers about invoices they owe you, and are intended for business to business invoices. You must not use them to collect a debt incurred by an individual primarily for personal, family or household purposes.

No sale or sharing. We do not sell personal information and we do not share it for cross-context behavioural advertising. We have not done so in the preceding twelve months.

Our service provider commitments. Where we act as your service provider we: process personal information only for the limited and specified business purposes set out in our agreement with you; do not retain, use or disclose it for any other purpose, or outside our direct business relationship with you, except as the CCPA permits; do not combine it with personal information we receive from or on behalf of anyone else, or that we collect from our own interaction with the consumer, except to perform a permitted business purpose; provide the same level of privacy protection as the CCPA requires of you; notify you if we determine that we can no longer meet our obligations; and allow you to take reasonable and appropriate steps to stop and remediate any unauthorised use. We impose equivalent obligations on any subcontractor we engage.

Categories of personal information. Identifiers, such as name, business email address, business telephone number, username and account identifiers; commercial information, such as invoices, receivables, transactions and records of services purchased; accounting information, such as ledgers, invoices and reports; internet and network activity, such as IP address, log-in data, device and browser information and usage of the service; professional information, such as job title and role within your business; and, where the email functionality is used, email content, including replies and attachments received through a connected mailbox or through an address we operate on the customer organisation's behalf, as described below.

We do not collect bank account information in the United States. Bank account information is collected only for invoice finance and for open banking connections, neither of which we offer in the United States. Where you pay us for a subscription or an upgrade, your payment details are collected and held by our payment provider and not by us; we do not receive or store payment card numbers or card security codes.

Email content and connected mailboxes. The credit control features send payment reminders, statements and related messages on your behalf, in one of two ways.

If you connect your own mailbox: where that mailbox is Microsoft or Outlook, we also have access to the content of replies to those messages, including any attachments, so that we can show them to you and track the conversation. Where it is Gmail, we can only send messages, and have no access to your inbox, to replies, or to any other message.

If you do not connect a mailbox, messages are sent from an email address that we operate on your behalf. Replies are delivered to that address, and we receive and record them so that we can show them to you alongside the relevant invoice.

Sensitive personal information. We do not seek to collect sensitive personal information, and we do not use or disclose any for purposes that would give you a right to limit its use. Email content is capable of being sensitive personal information under the CCPA where the business is not the intended recipient of the message. The messages we process are the customer organisation's credit control correspondence: whether they are sent from its own mailbox or from an address we operate on its behalf, they are sent at its direction and the replies are meant for it, so the customer organisation is the intended recipient. We process them only on its instructions, to provide the email features it has asked for. We do not use email content to infer characteristics about anyone, and the additional restrictions in the 'Additional restrictions on the use of Third Party User Data' section of this policy apply.

Sources. We collect this information from the customer organisation and its authorised users; from Sage, through the Sage connector; from the organisation's accounting software; from a mailbox connected to the service; from the organisation's own business customers and other correspondents when they reply to messages sent through the service; from commercial credit reference and business data providers; and automatically from use of the service.

Purposes. To provide, secure, support and improve the credit control, risk insights and related services; to send, receive, record and display credit control communications and replies to them; to manage our relationship with the customer organisation; to make business credit information available to it; to keep the service secure and investigate misuse of it; and to comply with law.

Disclosures for a business purpose. We may disclose the categories above to our cloud hosting and infrastructure providers, commercial credit reference and business data providers, email, messaging and integration providers, Sage, and our professional advisers, in each case for a business purpose.

Our payment provider. Where you pay us, your payment is processed by Stripe Payments Europe, Limited. Stripe processes some information as our processor, to service its platform and to provide its products and services to us. For much of what it does, however, Stripe acts as an independent controller and determines the purposes and means itself. That includes selecting the banks and payment method providers used, detecting and preventing fraudulent transactions, managing financial loss and security risks, meeting its anti-money laundering and know-your-customer obligations, and analysing and improving its own products and services. Stripe does this under its own privacy notice, and we do not control that processing.

Retention. We retain personal information for the periods described in section 8, so far as those periods apply to the services we provide in the United States, and for no longer than is reasonably necessary for the purposes for which it was collected. Where we hold information as your service provider, we retain it for as long as our agreement with you requires and delete or return it on termination.

Your US privacy rights. Subject to verification and to the exceptions in applicable law, you may have the right to know what personal information we collect, use and disclose; to access it and obtain a copy; to correct inaccurate information; to delete it; to opt out of any sale or sharing, noting that we do neither, and of profiling in furtherance of decisions that produce legal or similarly significant effects, which we do not carry out; to limit the use of sensitive personal information; and not to be discriminated against for exercising any of these rights.

We use profiling only for marketing and to improve the services. You can object to profiling for direct marketing at any time, and if you do we will stop.

How to exercise your rights. Contact us using the details in section 2.2. You may use an authorised agent. We will verify your identity before responding. Where we hold the information on behalf of the customer organisation that supplied it, we will refer the request to that organisation and assist it in responding. Where we decide how and why the information is used, as described above, we will handle the request ourselves. Where the request concerns information held by Sage, you will need to contact Sage. If you use an authorised agent, we will ask for written authorisation signed by you and will verify the agent's identity as well as your own, unless the agent acts under a valid power of attorney, in which case we will verify that authority instead.

Other states. Where a US state privacy law applies to personal information we hold, we will honour the rights it gives you. To exercise a right, contact us using the details in section 2.2.

Deidentified information. Where we hold information in deidentified form, we will maintain and use it only in that form, will not attempt to reidentify it except to test whether our deidentification is effective, and publicly commit to those obligations by this statement.

Opt-out preference signals. Some browsers and extensions can send an automated signal, such as Global Privacy Control, asking that your personal information is not sold or shared. We do not sell or share personal information, so there is no sale or sharing for such a signal to stop. Where we receive one, we will treat it as an instruction not to sell or share your personal information and will continue not to do so.

International element. We host the services on cloud infrastructure located in Ireland, and we are based in the United Kingdom. Personal information you provide in the United States will therefore be processed in Ireland and the United Kingdom. Transfers from the United Kingdom to Ireland are covered by the United Kingdom's adequacy regulations for the European Economic Area, and transfers from Ireland to the United Kingdom are covered by the European Commission's adequacy decision for the United Kingdom, so no additional safeguard is required in either direction. Where we transfer personal data out of the United Kingdom to a country without adequacy, we use the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Where a transfer is made out of the European Economic Area to such a country, we use the EU Standard Contractual Clauses. Where we rely on the UK International Data Transfer Agreement, the UK Addendum or the EU Standard Contractual Clauses, we carry out the applicable transfer risk assessment or data protection test. Those assessments do not apply where a transfer relies on adequacy. Where we transfer personal data to Sage in the United States, we rely on those mechanisms or, where the recipient is certified, the UK Extension to the EU-US Data Privacy Framework for transfers originating in the United Kingdom and the EU-US Data Privacy Framework for transfers originating in the European Economic Area.

Onward transfers by our providers. Some of the providers described in this Addendum make their own international transfers. In particular, our payment provider transfers personal information to Stripe, LLC in the United States, and Stripe and its affiliates may transfer it on a global basis as necessary to provide their services, under the transfer mechanisms in their own data processing agreement. Where a provider acts as our processor, its transfers are governed by our data processing agreement with it. Where it acts as an independent controller, it makes those transfers under its own privacy notice and transfer arrangements, which we do not control.

Addendum: Embedded Accounting Services (Sage)

This Addendum applies where you use our embedded accounting functionality, an accounting front-end that we provide, powered by accounting and tax-filing services made available to us by Sage through its application programming interface (a "headless" service). The embedded accounting functionality is available to customers in the United Kingdom only. This Addendum applies in addition to the rest of this policy.

Our role (controller). For the personal data that you and your authorised users enter into, or generate through, the embedded accounting functionality, Satago acts as a controller. Where you process your own customers' or employees' personal data through it, you act as controller and Satago as your processor, as described in section 2.1.

Sage's role (our processor). Sage provides the underlying accounting and tax-filing engine and, in respect of that processing, acts as our processor on our documented instructions under a data protection agreement that meets Article 28 UK GDPR. Sage may engage sub-processors under a general authorisation. Sage maintains a list of them and tells us about a change where it considers the change to have a material effect on the service. Where we are told, we will pass that on to you, and you may reasonably object to the change within thirty (30) days by contacting us. For certain regulated filings, for example submissions to HM Revenue & Customs under Making Tax Digital, Satago and Sage may each act as independent controllers and share data on a controller-to-controller basis for that purpose.

Data we process. This may include your and your authorised users' identity and contact details; business profile and registration details; bank account and transaction information; accounting ledgers, invoices, expenses and tax records; National Insurance numbers (where required for tax submissions); and technical/configuration data. We do not use this data for advertising or to train AI models. Where the service offers AI-assisted features, we will tell you before you use them and will only enable AI processing of your data on the basis agreed with Sage and permitted by law. Where you choose to use an AI-assisted feature, Sage may act as a controller in its own right for that processing rather than as our processor, and will do so under its own privacy notice.

Lawful bases and transfers. We rely on performance of our contract with you, compliance with legal obligations (including tax-filing obligations), and our legitimate interests in operating and improving the service. Where Sage or its sub-processors process your data outside the UK, transfers are protected by the UK International Data Transfer Agreement / the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision, consistent with section 6.