Privacy policy

Introduction & Definitions

This Privacy Policy, together with our Terms & Conditions document set forth the general Terms and Conditions (also mentioned as “Terms”) that apply to your access and use of all Cedolo.com products and Services (together, the “Cedolo.com Services” or “Services”), that are made available through our Sites including but not limited to all content and Services provided in the domain Cedolo.com, as well as through certain downloadable mobile applications or platforms that are authorized by Cedolo.com for providing our Services (together, the “Site”). “Cedolo.com” includes Cedolo.com, Inc. and its officers, directors, employees, consultants, affiliates, subsidiaries and agents.

By using or accessing the Cedolo.com Services you agree to these Terms, according to their latest updated version.

This privacy policy will help you understand how we collect, use and protect your personal data. You should also show this notice to anyone else who may be named or have personal data included in any quote, product or Service offered through us.

The language of the entire Terms documents, including the Privacy Policy is English. Where Cedolo.com has provided a translation of the English version of any part of the Terms, you agree that the translation is provided for your convenience only and that the English language version of the Terms will govern your relationship with us and the services that we provide to you. If there is any contradiction between the English language version of the Terms and its translation, then the English language version will take precedence.

You acknowledge that by providing your personal data to us, you consent to its processing in the manners outlined below. When providing personal data about others, you confirm that you have the consent of these individuals to supply their personal data. We are unable to offer you any product or Service that requires the processing of special category personal data, as defined in the General Data Protection Regulation (GDPR), unless you provide explicit consent for the collection and use of such data.

“we”, “us”, “our”, “Cedolo” refers to Cedolo.com, a trading name of Cedolo.com Ltd, a company registered in Finland, with the headquarters located at Juhana Herttuan puistokatu 3, Turku.

“you” and “your” means the person who accesses and uses our Site

I. Information we collect

Information we may collect directly from you

We may collect information directly from you when you use our Services — for example, when you register an account, when you request information for a financial product, when you request to contact us, when you link your third-party account to our Service, when you use interaction points such as sliders, calculators, text boxes, surveys, forms or other fields on our Site. In such cases, we may ask you to provide us with one or more of the following pieces of information:

• Name
• Email address
• Mailing address
• Phone number
  Date of birth
• Third-party account information
• Age, gender, or other demographic information
• Personal responses, emails, replies, reviews or other User Generated Content (UGC)
  Email data, self-reported data, or other data as collected on our email marketing campaigns via the Klaviyo.com platform. You can view the Klaviyo.com privacy policy here.

When this data is collected

We may collect your personal data when:

• You insert any data on our user interface, such as by filling our interactive sliders, pop-ups, search bars, forms, calculators and other points of interaction
• You request loan results or a quote for any Service available through our Site
• You make a purchase from a third-party provider following a loan result, or a quote using our Service
• You make customer enquiries via email, telephone, SMS, or other means of communication
• You register for information or other Services
• You respond to communications or surveys
• You participate in our giveaways or other contests
• We require additional information from you for validation purposes
• When you create any User Generated Data on our site, including but not limited to giving ratings, writing reviews, comments and in general engaging in any activity on our Forum.

Information automatically collected

Types of Information Collected

When you visit the Site, use the Services, or open an email from Cedolo.com, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation:

• IP address or other device address or ID.
• Web browser and/or device type.
• Geolocation data, including if you use the Site on a mobile device.
• Hardware and software settings and configurations.
• Web pages or sites that you visit just before or just after visiting the Site.
• Pages you view on the Site.
• Your actions on the Site.
• Dates and times that you visit, access, or use the Services.

Cookie Information

General Cookies description

When you use the Services, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. If you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Typically, they only contain two pieces of information; a site name and a unique user I.D.

How does Cedolo.com use cookies?

We use cookies to keep your user preferences and actions, in order to assist and optimize your overall experience of using our Site. These are known as essential cookies. Those cookies include actions such as creating or using your account in our site, writing reviews, interacting with existing reviews by giving likes or replies, writing other user content on the site, setting up custom search or filter preferences, accepting and saving user preferences (including privacy preferences), or any other action which affects the way you experience the Site. Those cookies are important to give you the best possible user experience.

We also use non-essential cookies, (also mentioned as “additional cookies”) – that help us to improve our online marketing and advertising efforts, and to further optimize your user experience on our Site. These cookies allow us to track your user actions and associate them with anonymous user data, with the assistance of 3rd parties and services such as Google Ads, Google Analytics, DoubleClick, Bing Ads, Gleam, Typeform, RedTrack, Google Tag Manager, Yahoo, Facebook, YouTube etc. We can use those data to optimize and even customize the service that we provide to you, and provide you with more relevant results and services. We may also use those data to find people with similar interest and actions with you, also known as lookalike audiences. We may also use those data to enhance our business operations, offerings, and profitability.

Most additional cookies can be disabled using the cookie consent settings banners. However, all cookies can be disabled using the information given in the section below titled “How do I manage my cookies”. It should be noted that if you choose to remove or disable all cookies, this may harm the way the website is intended to operate and result in reduced or inaccurate functionality.

Types of cookies we may use

This a list of cookies that our site may use, but not limited to

User action cookies

This a list of cookies that our site may use, but not limited to

Remember-me cookies

Allows us to remember your preferences e.g. saving you the trouble of typing in your user information every time. This includes your cookie settings preferences.

Custom tags/cookies

Allow us to track your actions in our Site and pass on information on inbound and outbound links and other 3rd parties you may visit and interact with. They also allow us to track your user-generated data actions. Those cookies usually include GTM(Google Tag Manager) tags, loan tags, URL tags, attribution tags, or UGC related tags.

Conversion cookies

Allow us to assign anonymous IDs (from Google Analytics IDs) to get data on the click or conversions values or actions that occurred on our site or on other 3rd party sites with the use of postback data.

Google Analytics

Allows us to collect anonymous information about how visitors use our Site including what devices they use. It also gives access to anonymous third-party audience data, including gender, age group and interests. You can read about Google’s Privacy Policy here.

Other marketing cookies

Third-party cookies that show us how you found our Site and which Site you came from, as well as to analyse your behaviour and actions within our Site. This helps us know how effective our online marketing is. Some may also allow us to create more targeted user audiences based on past user actions or create similar audiences (also known as lookalikes) that are based on current user behaviours and demographics to allow us to reach more potential users and customers. They also allow us to reward some external sites for directing you to us. Those third parties may include Google Ads, DoubleClick, Bing Ads, Gleam, Yahoo, Facebook, YouTube or others.

How do I manage my cookies?

You have the option to customize your cookie settings on Cedolo.com when you first enter our site, through the appropriate cookie consent banner.

Once, you select your cookie settings, those are saved for future use which is typically kept for 365 days. However, if you wish to do additional changes to your cookies you may change them at any point by using this cookie settings link.

By using the cookie settings screen may remove most cookies which are loading on the “other cookies” category, but you don’t have access to remove the essential cookies which are important for your user experience when using our site.

If you still want to remove even the essential cookies then you may follow the directions below:

Most browsers let you manage and block cookies from specific sites. You also have the option of only blocking third-party cookies, which still lets you get the best experience when using Cedolo.com. You can find out how to manage your browser cookie settings here.

Please note that by deleting or disabling cookies this could affect the functionality of our Site and you may not be able to access certain areas or features of our site.

Also, you can disable specific cookies related to Google & Facebook ad as shown here:

Google cookies

Facebook cookies

Additionally, you can read Google’s privacy policy here.

You may also read Facebook’s policy here.

Information from other sources

We may also obtain information about you from third-party sources, such as our partners or advertisers. We may also, at your direction, receive data from third-party services that provide a mechanism to share information you have provided to the third-party through the use of an application program interface (API), such as Facebook Connect or the Twitter API. If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Policy, the Terms, and applicable law.

II. How We Use Your Information

Your information is an integral part of our operations, and we use it in a variety of ways in providing the Services and operating our business. We use the information you provide, for example:

• To provide you the Services you request and enable third parties to provide additional Services to you.
• To operate, maintain and improve the Services and create new features and functionality.
• To understand and analyse usage trends and preferences of our users across different devices.
• For fraud detection and information security.
• We may use your e-mail address or other personal information (a) to contact you for administrative purposes such as customer Service, (b) to address intellectual property, right of privacy or defamation issues related to content you have posted on the Services, and/or (c) to send you promotional materials, offers, and/or messages related to the Services and the activities of third parties we work with. Generally, you can opt out of receiving promotional communications, through links provided in the messages, by updating your account preferences through the Services, or by contacting us directly at team@Cedolo.com.
• We may use Cookie Information and Automatically Collected Information to: (a) personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Services; (b) provide customized advertisements, content, and information across your devices; (c) monitor and analyse the effectiveness of Services and third-party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities.
• There are certain circumstances where we process your personal data for our legitimate business interests. These can be commercial or societal benefits and for us to process your data, we will always balance our interests against your own to ensure it is fair.
• The following processes rely on legitimate interest:
• Sharing data with our suppliers and Service providers in order to generate a service request of yours
• Fraud detection and prevention
• Engaging and contacting you throughout the lifecycle of your Cedolo.com account to ensure you have a good experience as a valued user.
• Engaging you and contacting you to remind you of our Service
• Internally auditing our processes to maintain our high standards
• Providing a summary of our Service
• Sharing data with selected third parties in order to add value to our products
• We also engage in online advertising, to keep you aware of what we’re up to and to help you see and find our Services.

III. How We Share Your Information

• We may disclose your information in connection with providing the Services and the operation of our business. For example, we may share personal information, such as name, email, address, and other identifying information, with third-party Service providers to verify your identity in connection with your use of certain aspects of the Services.
• We may share information collected directly from you with third-party lending partners or third-party Service providers in connection with your use of specific aspects of the Services. Some examples include but are not limited to:
• When you request to learn more information for a product on our Site.
• When you request additional or personalized information regarding our Service
• When you report a complaint about a product, or a third-party lending partner featured on our Site we may forward your complaint to that lending partner.
• When you request answers or advice through our Services, Cedolo.com may provide certain of your information to third party companies, advocates, and advisors.
• We may share automatically collected information such as IP address as well as de-identified information with third-party lending partners when you leave our Site (for example, from a review collection page) to go to a third-party lender site to request information or apply for financial products.
• We may share your information with third-party Service providers to support our internal and business operations. In such cases, Service providers may use the information only as necessary to provide the Services to us and are contractually required to keep your information confidential and 0secure. For example:
• For Site, application development, hosting, data storage, maintenance, and other Services for us.
• For internal marketing, delivery of emails, including promotional, marketing and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising.
• For fraud prevention and security purposes.
• When you choose to share your own information on a publicly accessible area of the Site, such as a public profile page or any section where you can publicly submit questions to us or our third-party partners, that information will be available to anyone who is able to access that content, including other Site users. Additionally, questions you submit, and answers provided by third parties may be posted on our Site and viewable by other users and the public.
• We may share de-identified and/or aggregate analytics with third-party partners about how users interact with our Services, including usage patterns for certain programs, content, Services, advertisements, promotions, and/or functionality available through the Service.
• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
• By submitting a request through our Services, you consent to the disclosure of your information to third parties in order for us to carry out your request. The collection and use of your information by third parties is subject to each third party’s specific privacy policy and terms of use. Cedolo.com has no control over the means by which third parties further use or disclose your information.
• If you submit a request through our Services, a third-party Service provider may directly contact you with relevant information via telephone, fax, and/or email. You may also receive telemarketing calls as a result of submitting the request, even if you are on the National Do Not Call Registry or any other similar registry.

Do not submit a request for information or Services if you do not want your personal information shared as described above. Once you have submitted a request through the Services and we have shared your information as described above, the terms of the third party’s privacy policy will apply to that party’s use of your information.

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

IV. Account information & Data Rights

You have the following rights when it comes to your account information or the data that is related to your use of the Service:

Unsubscribing from emails

If you do not wish to receive email offers or newsletters from us, you can opt-out of receiving email information from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any marketing email from us. Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. If you wish to be excluded from all other user databases as well wherever possible, please inform us at team@Cedolo.com

Reject Services & Consultations

You have the option to refuse any free consultations or offers for Services provided after you submit a request to a third party through the Services.

Request your data

In order to access the data, we hold about you, you need to make a ‘Subject Access Request’, or SAR. To make a SAR please email us at: team@Cedolo.com

Please provide:

Your full name, physical address, email address, phone number
Latest utility bill on your name verifying your physical address and phone number
What information you would like to receive
Once we have received your written request and documents, we will have 30 calendar days to fulfil your request. Where for some reason this will not be possible, for instance, due to large volumes of data being involved, we are permitted by law to take up to an additional 60 days to fulfil your request. Where any such delay is anticipated we will inform of you this as soon as possible along with details of when we expect to be able to provide you with the requested documentation.

Retention of your data

Your personal data will be kept for as long as we require it in order to provide you with the agreed product(s) or Service(s), It will continue to be retained after any account or Service has been closed or otherwise come to an end in line with legal and regulatory requirements.

There are specific more sensitive data that Cedolo.com deletes in more regular periods, such as voice messages emails, which should be deleted 2 years after they were first received.

Other data rights

Your other rights as a data subject, where applicable, include:

• The right to be informed about our processing of your personal data
• The right to have your personal data corrected if it is inaccurate, and to have incomplete personal data completed
• The right to object to the processing of your personal data
• The right to have your personal data erased (“right to be forgotten”)
• The right to move, copy, or transfer your personal data (“data portability”)
• Rights regarding automated decision making, including profiling

Data Requests

For more details on these rights and how to exercise them, please contact: team@Cedolo.com

If you have any queries about your data rights, or believe that they have not been met by Cedolo.com, please contact our Data Protection Officer at team@Cedolo.com

or by writing to:

Codeworks Ltd

Juhana Herttuan puistokatu 3

20200, Turku

Finland

V. Our Commitment to Data Security

General data policy code of conduct

We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Services or store on the Site, and you do so at your own risk.

Confidentiality and disclosure of your data

We will endeavour to treat your personal data as private and confidential. From time to time we may employ agents and subcontractors to process your personal data on our behalf. The same duty of confidentiality and security will apply to them and all processing will be carried out under our instruction.

We would like to bring to your attention our obligations to disclose data in the following four exceptional cases permitted by law, and the other situations set out below. These are:

• Where we are legally compelled to do so
• Where there is a duty to the public to disclose
• Where disclosure is required to protect our interest
• Where disclosure is made at your request or with your consent
• If you make a complaint about the Service we have provided, we may be obliged to forward details about your complaint, including your personal data, to the relevant ombudsman. You can be assured that they are similarly obliged to adhere to the requirements of the GDPR and keep your personal data strictly confidential.

Please note that we and our suppliers may make several checks to assess an application for finance or verifying identities to prevent and detect crime and money laundering, as well as data sharing at any time for the purposes of fraud prevention.

Fraud prevention and detection

In order to prevent and detect fraud, insurers and other Services may at any time share information about you with members of Cedolo.com

In addition, we actively monitor information entered into our Site and pass on intelligence of suspected fraud to other parties including insurance providers, financial institutions and fraud prevention agencies. Law enforcement agencies may access and use this information.

We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

• checking details on applications for credit and credit-related or other facilities
• managing credit and credit-related accounts or facilities
• recovering debt
• checking details on proposals and claims for all types of Insurance
• checking details of job applicants and employees

Complain to the Supervisory Authority

If you have any complaints relating to the processing of your personal data, you also have the right to complain to the relevant Supervisory Authority.

VI. Changes to This Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time. We will notify you about material changes in the way we treat your information, including by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Services. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Terms. Immaterial modifications are effective upon posting of the updated Privacy Policy or Terms of Service on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

VII. Our Contact Information

If you have any further questions, don’t hesitate to contact us. You can email us team@Cedolo.com, or write to us at:

Codeworks Ltd

Juhana Herttuan puistokatu 3

20200, Turku

Finland

Last Update

These Terms and Conditions were last updated on October 11th, 2021