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Ver. 7.0 – 17/04/2025

Soldo understands that your privacy is important to you and that you care about how your personal data is used.

This privacy policy aims to give you information on how Soldo collects and processes your personal data in the context of supplier and consultant relationships or when otherwise working with us as an external person.

This privacy policy applies to personal information of suppliers (including vendors) or potential suppliers who are natural persons such as self-employed persons, and representatives or
contact persons or other employees of suppliers, or potential suppliers, who are legal entities.

About Soldo

Soldo is made up of different legal entities.

This privacy policy is issued on behalf of the Soldo companies, so when we mention “Soldo”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant Soldo legal entity responsible for processing your personal information.

For the purposes of the European and UK data protection law, the Soldo company that you have dealings with is the controller of your personal information, for further details of which, please see the “Contact details” section below. This means that we are responsible for deciding what data is collected, how this data is going to be used e and how this data is
protected.

We are required under the data protection laws to notify you of the information contained in this privacy policy. It is important that you read this policy, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Contact details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer at [email protected]

You can contact Soldo Financial Services Ireland DAC as follows:
Address: 33 Sir John Rogerson’s Quay, Dublin 2, D02 XK09
Email: [email protected]

You can contact Soldo Software Ltd as follows:
Address: 119 Marylebone Road, London NW1
Email: [email protected]

You can contact Soldo Financial Services Ltd as follows:
Address: 119 Marylebone Road, London NW1
Email:` [email protected]

You can contact Soldo Italia Srl as follows:
Address: Via degli Olivetani 10/12, Milano
Email: [email protected]

You can contact Soldo Technology Srl as follows:
Address: Via degli Olivetani 10/12, Milano
Email: [email protected]

You have the right to make a complain to the Data Protection Authority of the state of your usual place of residence, place of work or place of the alleged infringement. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance.

What is personal data?

Personal data is defined as any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.

This personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What personal data do we collect?

We may collect information directly from you and the company with which you are working (for example, your employer).

We may also receive information from our related companies or third-party sources such as public databases or social media.

Certain personal information is required as a consequence of any contractual relationship we have with you or your company, to enable us to carry out our contractual obligations to you or
your company. Failure to provide this information may prevent or delay the fulfilment of these obligations.

The information we collect may include:

• general information: name, company name, department, job title, gender, email and/or postal address, mobile phone number, date of birth;
• personal data that are necessary for signing documents, including signature and authorisations;
• bank account and tax-related information where it relates to an individual, such as if you are operating as a sole trader;
• references, CV and details of individual’s employment history, if collected as part of a bidding or engagement process;
• in some cases, we may collect your voice data obtained through audio recording, and any data included in the recording;
• images and voice data obtained through video and audio recording;
• any other personal information necessary to fulfil the terms of a contract we have with you.

Why do we collect and use your data

Our purpose for collecting your personal data is so we can:

• manage our contract with you, including processing information in response to our request for quotation, signing documents, sending related information and purchase orders;
• process payments to you in accordance with our contract with you;
• keep records of the suppliers that we use. We keep and update your personal data in our suppliers database in order to contact you and/or your company when we need goods or services that you or your company can provide;
• comply with a legal obligation to which we are subject;
• conduct auditing activities to ensure we comply with applicable laws and regulations, and internal policies;
• conduct supplier audits, including risk assessment. We process your personal data to evaluate the organizational and technical performance of your company, as well as fulfilment of agreed processes or specific standard or regulation requirements;
• conduct systems access control where we provide you with access to our IT systems;
• provide a remote access VPN and IT support to ensure secure access to and use of our resources, including collaboration tools;
• record incoming calls for fraud prevention and compliance purposes (as a customer support team member, if you receive a call from a customer reporting fraud);
• record sales calls using videorecording tools for coaching purposes. This allows us to provide constructive and specific feedback on conversations our sales team has with customers and potential customers. Additionally, it helps us establish best practices for sales calls that will guide the entire team. Only direct managers, sales enablement and sales leadership will have access to listen to the call recordings;
• respond to and defend against legal claims.

The lawful basis for processing your data

The lawful basis we rely on for processing your personal data in relation to information we collect and process as part of the contract process, including making payments to you, is that
it is necessary for the performance of a contract to which you are a party.

The lawful basis we rely on for processing your personal data for accounting purposes, is our legal obligation in national law to retain certain personal data for a specified number of years.

We may also process your personal information where it is necessary to pursue our legitimate interests (or those of a third party), provided that your interests or your fundamental rights and freedoms do not override our interests. Our legitimate interests include: keeping records of the suppliers, performing internal and certification audits, conducting supplier audits, conducting systems access control, incoming call recording for fraud prevention, sales calls recording for coaching purposes, responding to and defending against legal claims.

How long do we keep your data for?

We will keep your personal data for as long as is necessary for the purposes it was collected.

Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory retention requirements.

Data security

We take the security of your personal data seriously. All personal data you provide to us will be stored securely in accordance with our policies.

We implement appropriate technical and organisational measures that comply with the relevant applicable laws and regulations, to ensure your personal data is adequately protected from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, when transmitted, stored or otherwise processed.

We restrict access of your personal data to those persons who have a business reason for knowing such information. We continuously educate and train our staff about the importance
of confidentiality and data protection.

All our suppliers who process personal data for us are required to keep that data secure.

Data store

Personal data is held in data centres within the European Economic Area (EEA).

Data sharing

Your information may be processed by our staff or by the staff of other companies we work with to deliver our business.

The data we collect may be shared between Soldo companies or with suppliers that provide us with technology, administrative support and communication services to help us manage our relationship with you.

All the recipients of your personal data are required to take appropriate security measures to protect your personal data. They must only process your personal data for specified permitted
purposes and in accordance with data protection laws.

We, or processors acting on our behalf, will only process personal data in countries outside the EEA and the UK, when we are assured, those countries provide an adequate level of data protection. In absence of an adequacy decision, transfer will be made on condition that individual’s enforceable rights and effective remedies are available, and appropriate safeguards are in place.

We will share your data if we are required to do so by law, for example, by court order, or to prevent fraud or other crime.

Your rights

We ensure you can exercise your rights in relation to the personal data you provide to us.

You can request access to the personal data we hold about you at any time.

You can also ask us to update your personal data if it changes or it is incomplete. In certain circumstances, you can request we erase the personal data we hold or ask us to stop or
restrict processing if you have an objection.

You have the right to object to us processing your personal information based on our legitimate interest unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims.

In some circumstances, you may be entitled to obtain your personal data from us in a format that makes it easier to reuse your information in another context and transmit this data to another data controller of your choosing without hindrance. This is referred to as the right to data portability. The right will only apply to the information you have provided and where it is held electronically, and where you have either consented to processing, or where processing is conducted on the basis of a contract you have with us.

If you have any privacy-related questions or unresolved problems relating to the use of your personal data, you can contact us at [email protected].

You have the right to make a complaint at any time to the relevant data protection authority.

We would appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.

Changes to this policy

We may update this privacy policy from time to time. In that case the last updated date at the bottom of this page will also change. Any changes to this privacy policy will apply to you and your data immediately.

Last updated 17 April 2025

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Ver. 6.1 – 17/07/2026

Soldo recognises the importance of protecting your personal data and is committed to handling it responsibly and transparently.

This Privacy Notice explains how Soldo collects and processes personal data in connection with applications for employment.

It applies to candidates and potential candidates whose personal data is processed as part of the recruitment process, including individuals who are successful and receive a job offer.

It does not apply to personal data relating to employees, independent contractors, or customers of Soldo, which is subject to separate privacy documentation, applicable to those categories of individuals.

Please read this Privacy Notice together with any additional privacy information we may provide from time to time, so that you understand how and why we use your personal data.

About us

Soldo operates through several legal entities.

Soldo Software Ltd acts as the controller of the personal data processed during the job application and recruitment stages, meaning it determines how and why your personal data is processed.

If you are offered a role, the relevant Soldo company will act as controller for the offer and related processing activities. Should you accept, you will be employed directly by that company.

In this Privacy Notice, “Soldo”, “we”, “us” or “our” refer to the relevant Soldo company acting as the controller of your personal data.

How to contact us

If you have any questions about this Privacy Notice or wish to exercise your rights under applicable data protection laws, please contact the Data Protection Officer (DPO) at [email protected].

The contact details of the Soldo companies acting as controller are set out below:

Soldo Software Ltd
119 Marylebone Road, London NW1, United Kingdom
[email protected]

Soldo Financial Services Ireland DAC
33 Sir John Rogerson’s Quay, Dublin 2, D02 XK09, Ireland
[email protected]

Soldo Financial Services Ltd
119 Marylebone Road, London NW1, United Kingdom
[email protected]

Soldo France SaS
Address: 23 rue d’Anjou 75008 Paris, France
[email protected]

What personal data we collect

We collect your personal data through the application and recruitment process, either directly from you, from other Soldo companies, or from third parties.

This may include information provided in application forms (submitted by post or through our website), CV or résumé, identity documents such as passports or national identity cards, or details obtained during interviews or other assessment activities.

We may also receive information about you from recruitment agencies or consultants, former employers, background screening providers, and online professional platforms, e.g. LinkedIn.

Some of the information we collect about you is required to make an assessment of your application and contact you about your progress through the recruitment process (for example, your telephone number, email address, CV). If you do not provide this information then we will be unable to assess your application or contact you to invite you to interview.

The information we collect may include:

• your name, postal address, email address, phone number, contact details;
• age range;
• gender;
• nationality;
• current salary, annual leave, pension and benefits information;
• desired start date with Soldo;
• details of your educational history, qualifications, skills, experience and employment history;
• cover letter and references from previous employer;
• copy of passport and other identification;
• photographs;
• information about your entitlement to work in the country (where applicable).

In principle, we do not collect or otherwise process special categories of personal data (such as health-related or other sensitive details), unless you choose to share them with us as part of your application or during the recruitment process.

We will only process special categories of personal data where you have given your explicit consent or where it is necessary for us to comply with our obligations or exercise specific rights under employment or equality legislation (for example, to assess any reasonable adjustments you may require).

For certain roles, we may be required to obtain information relating to criminal convictions and offences. Where this is the case, we will do so only where it is necessary to comply with our legal obligations or to exercise specific rights in connection with employment, and in accordance with applicable legislation.

Why we use your personal data

We process your personal data for the following purposes:

1. Job applications and candidate assessments
   to review and assess your application, including evaluation of your skills, qualifications and suitability for the relevant role.
2. Recruitment administration and candidate records
   to administer recruitment activities, analyse recruitment channels and maintain candidate records, including details of unsuccessful applicants for potential future opportunities.
3. Pre-employment checks and legal compliance
   to carry out pre-employment checks and comply with legal obligations, including verification of your right to work and, where permitted or required by law, background checks.
4. Job offers
   to make and manage an offer of employment, including related communications and administrative steps.
5. Legal claims and dispute management
   to establish, exercise or defend legal claims.

We will not use your personal data for purposes other than those set out above.

Lawful basis for processing

We process your personal data on the lawful grounds permitted under applicable data protection laws.

Pre-contractual steps

Some of the personal data we process is necessary to take steps at your request prior to entering into an employment contract, including reviewing and assessing your application and considering your suitability for a role.

Legitimate interests

We may also process your personal data where it is necessary for our legitimate interests (or those of a third party), provided that your interests or fundamental rights and freedoms do not override those interests. This includes managing and administering the recruitment process, improving the efficiency, consistency and quality of candidate assessments and interview documentation, proactively identifying and sourcing suitable candidates for current or future roles, retaining candidate records (including unsolicited applications), and establishing, exercising or defending legal claims.

Legal obligations

We also process your personal data to comply with our legal obligations, including verifying your right to work or carrying out other pre-employment checks required by law.

How we share your personal data

Your personal data may be shared among Soldo companies in connection with the administration and support of the recruitment process. This may involve access to your personal data by members of the People Team, hiring managers and interviewers involved in the selection of candidates.

If you are selected for a role with a specific Soldo company, your personal data will be shared with that company to progress your application and, where appropriate, to make you an offer.

Such sharing may also involve transferring your personal data within the European Economic Area (EEA) or the UK, or between the EEA and the UK.

We may also share your personal data with external service providers, including providers of hosting, IT and communication services (including services for the generation of interview transcripts, notes and summaries), as well as recruitment agencies supporting our recruitment activities.

All recipients of your personal data are required to implement appropriate security measures to protect it. They may process your personal data only for specified purposes and in accordance with data protection laws.

International transfer of your personal data

Where personal data is transferred outside the EEA or the UK, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws. These safeguards may include transfers to countries recognised as providing an adequate level of protection, the use of the European Commission’s Standard Contractual Clauses (SCCs) and, where applicable, the UK International Data Transfer Addendum (UK Addendum).

We may also rely on the EU-US Data Privacy Framework (EU-US DPF) for transfers from the EEA to certified organisations in the United States, or on the UK Extension to the EU-US DPF for transfers from the United Kingdom to such organisations.

How long we keep your personal data

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected.

If you apply for a vacancy and you are unsuccessful, your personal data will be stored for twelve months following the closing date of the relevant vacancy in order to manage our recruitment records and consider you for future employment opportunities. We may retain your data for a longer period where necessary to establish, exercise or defend legal claims.

If you are successful, your personal data obtained during the recruitment process will form part of your personnel file and will be retained for the duration of your employment by the relevant employing Soldo legal company. Details of the applicable retention periods will be provided in the employee privacy notice issued by that company.

Where interview transcripts, notes or summaries are generated during the recruitment process, they will be retained as part of the relevant recruitment or employment records, in accordance with the applicable retention period set out above.

How we protect your personal data

We take the security of your personal data seriously. All personal data you provide to us will be stored securely in accordance with our policies.

We implement appropriate technical and organisational measures to ensure your personal data is adequately protected from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, when transmitted, stored or otherwise processed.

Access to personal data is restricted to individuals who have a legitimate business need to know such information. We continuously educate and train our staff on the importance of confidentiality and the protection of personal data.

All our suppliers who process personal data on our behalf are required to implement appropriate security measures to protect it.

Automated decision-making and AI-assisted tools

As part of the recruitment process, we may use AI-assisted tools to support certain activities, such as the pre-screening of applications and the translation of technical information contained in CVs, and the generation of interview transcripts, notes or summaries during interviews. These tools are used solely to assist the recruitment team and do not replace human review. All recruitment decisions are subject to meaningful human involvement.

Where AI-assisted interview transcription, note-taking or summarisation is used, you will be notified before or at the beginning of the interview. This processing is carried out on the basis of our legitimate interests. You have the right to object to the use of these AI-assisted features, in which case the interview will continue without them.

No decision that produces legal or similarly significant effects concerning you is based solely on automated processing.

Your data protection rights

We are committed to ensuring that you can exercise your rights in relation to your personal data.

Under applicable data protection laws, you have several rights regarding the personal data we hold about you. In particular, you may have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request the erasure of your personal data in certain circumstances;
• request the restriction of processing;
• object to the processing of your personal data where we rely on our legitimate interests as the legal basis for processing.
• receive the personal data you have provided to us in a structured, commonly used and machine-readable format and transmit it to another data controller. This right applies where the processing is carried out by automated means and is based on your consent or on a contract with us.

Where you object to processing based on our legitimate interests, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing is necessary for the establishment, exercise or defence of legal claims.

Where we rely on your explicit consent to process special categories of personal data, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before your consent was withdrawn.

If you have any questions about how we use your personal data, you can contact us at [email protected].

You can lodge a complaint with the data protection authority in the country where you live or work. For example:

• United Kingdom – Information Commissioner’s Office (ICO) – here
• Ireland – Data Protection Commission (DPC) – here
• France – Commission Nationale de l’Informatique et des Libertés (CNIL) – here
• Other EEA countries – European Data Protection Board list of supervisory authorities – here

We would, however, appreciate the opportunity to address your concerns before you approach the authority, so please contact us in the first instance.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time.

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