1. 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.

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.

2. 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 120 Regent Street, London, W1B 5FE. 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.

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, 120 Regent Street, London, W1B 5FE

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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 the 22nd February 2023.

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 and payment card details and information relating to your accounts and receivables. For further information on this refer to the ‘Financial Data' section of 'How we uee 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. 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’.

• 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 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). Nor do we collect any information about criminal convictions and offences.

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.

3. 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, GoCardless and AppDirect;

Identity and Contact Data from data brokers or aggregators such as SmartCredit Ltd, Creditsafe Business Solutions Limited and RSM Tracker;

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

Third Party User Data from parties such as Google, including Gmail, and Microsoft, including Office365/Outlook

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. You have the right to withdraw consent to marketing at any time by contacting us.

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.

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 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 re structuring 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 comply with our legal obligations including the prevention of financial crime.
​Type of data: (a) Identity; (b) Contact; (c) Transaction; (d) Third Party User Data
​Lawful basis for processing including basis of legitimate interest: To comply with a legal obligation

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 provide a web email client that allows users to compose, send, read, and process emails.

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.

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. 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.

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.

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 if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

You may also receive marketing communications from us if you have affirmatively opted in to receive such communications [or if your email address is associated with a corporate body (such as a limited company, limited liability partnership in England, Wales and Northern Ireland or any partnership in Scotland, schools, government departments and agencies, hospital trusts and other public bodies).

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.

5. 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.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The country to which we transfer your personal data is subject to UK adequacy regulations under which it has been deemed to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use standardised International Data Transfer Agreements approved by the Information Commisisoner, or an Addendum approved by the Information Commissioner applicable to specific model contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based outside the EEA, we may transfer data to them if the country in which they will process your data has been found by the UK government to provide adequate levels of data protection, or once we have put in place an International Data Transfer Agreement (or an addendum to standard contractual clauses issued by the European Commission in order to protect your data which has been approved by the Information Commissioner). Where we use these Agremeents or Addenda, we will conduct a risk assessment to ensure we are comfortable that the measures we have taken provide enough protection taking into account the local legal framework and we will work with our overseas providers to actively identify any potential risks to your data.

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

7. 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.

8. 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.

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.

9. 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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 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.

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.

10.2 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, such as financial products managed by Satago SPV1 Limited.

10.2.2 External Third Parties

Service providers who provide payment processing services.

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.

If you apply for our invoice financing services: Credit reference agencies and fraud prevention agencies who provide information on your company’s credit behaviour, and external funding partners. Further information on this is set out in the Invoice Finance section.

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. 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.