Privacy Policy

Effective date: Oct 4, 2023

Welcome to WLDD Private Limited (“Company,” “we,” “us” or “our”), a mobile technology company specializing in finance and accounting related tech products. Our goal is to move forward mobile money and finance management to the next level using neural networks, deep learning and data analytics technics. We aim to create new ways for people to maximise their profits through the technology and accounting.

This Privacy Policy (this “Privacy Policy”) describes:

  • The types of information we may collect or that all users or others may provide while downloading, installing, registering with, accessing, or otherwise using (“Users”, “you” or “your”, as applicable) our mobile application Solo (“Solo” or “application”).
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies only to information we collect in Solo and via email, text, and other electronic communications sent through or in connection with Solo.

We undertake to build Solo and any of its features in such a way that it respects your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy not only allows you to understand what we do with your Personal Data (as defined below), but also to manage your Personal Data effectively.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By downloading, installing, registering with, accessing or using (“Using”) Solo, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, do not Use Solo.

By Using Solo you understand and agree that we are providing a platform for you to better use the financical instruments available to you. If you have any questions about this Privacy Policy or Solo, please contact us (for contact information, please, see How to Contact Us Section).

This Privacy Policy DOES NOT apply to the information that:

  • We collect offline or on any other our apps or websites, including websites you may access through Solo.
  • You provide to or is collected by any third party, including through any other application or content that may link to or be accessible through Solo.

Our websites and other apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

This Privacy Policy may change from time to time (see Changes to Our Privacy Policy Section). Your continued use of Solo after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect several types of information, including but not limited to Personal Data, from and about you:

  • Directly from you when you provide it to us.
  • Automatically when you Use Solo. Information collected automatically may include Usage details, internet protocol (“IP”) addresses and information collected through cookies and other tracking technologies.
  • From third parties, for example, our Service Providers (as defined below).

To the extent information is: (i) associated with an identified or identifiable natural person and (ii) protected as personal data under applicable data protection laws, such information is referred to in this Privacy Policy as “Personal Data”. Please bear in mind that provisions of Section 5 do not apply to your pseudonymized Personal Data.

2. INFORMATION YOU PROVIDE TO US DIRECTLY

When you Use Solo, we may ask you to provide certain information, including your Personal Data:

  • data that you provide when you use Solo, via self-entry or reading contacts (if you have granted us permission to access your contacts). You may revoke permission to access your contacts through the settings on your mobile device. Please note that while we do not require or request any metadata attached to the data you upload, metadata (including, for example, geotags) may be associated with your data by default.
  • Information that you provide by interacting with Solo. This includes information provided at the time of Using Solo, purchasing certain enhanced features of Solo, requesting further services through Solo, and filling in forms in Solo. We may also ask you for information when you report a problem with Solo.
  • Details of your in-app subscriptions in Solo.
  • If you contact us, records, copies of your correspondence with us and contact details that you have provided us while making your inquiries (such as your name, postal addresses, email addresses and phone numbers or any other identifier by which you may be contacted online or offline), in order to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other Users inquiries in relation to Solo.

Your data are shared and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your data. Therefore, we cannot and do not guarantee that your data will not be viewed by unauthorized persons.

3. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

When you Use Solo, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Usage details. Details of your Use of Solo, including traffic data, logs and other communication data and resources you use through Solo.
  • Device information. Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, browser type and mobile network information.
  • Stored information and files. Please note that while we do not require or request any metadata attached to the data you upload to Solo, metadata (including, for example, geotags) may be associated with your data by default.

The information we collect automatically under this Privacy Policy may include your Personal Data and information we may maintain or associate with your Personal Data that we collect in other ways or receive from third parties. It helps us to improve Solo and to deliver a better and more personalized service, including but not limited to enabling us to estimate our audience size and Usage patterns and recognize when you Use Solo.
We collect the following categories of your personal information: identifiers, commercial information, internet or other electronic network activity information, geolocation data, and inferences drawn from these categories.

If the information covered by this Section 3 is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.

The technologies we use for automatic data collection may include:

Third-party analytics. We use third-party analytics tools, such as Google Firebase, Facebook Analytics, AppsFlyer, Kochava and Amplitude, to help us measure traffic and usage trends for Solo. These tools collect information sent by your device or Solo, including the web pages you visit when following the links available to you on Solo. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User. For information on how third-party analytics tools collect and process your data and to opt out of such collection and processing, generated by your Use of Solo, please visit the following link.

Cookies (or mobile cookies) and similar technologies. A cookie is a small file placed on your smartphone. When you Use Solo, we may use cookies and similar technologies to collect information about how you Use Solo and provide features to you. We may ask our Service Providers to serve services to your devices, which may include cookies or similar technologies placed by us or such Service Providers (on our request). You may refuse to accept mobile cookies by activating the appropriate mobile browser setting on your smartphone. You may also block, delete or disable saving cookies on your device. You can turn the cookies off by choosing the appropriate settings of your browser. The following links might be useful for you to choose the best option of your browser:

For the users of Chrome on Android and iOS.

For the users of Safari on iOS.

However, if you select these mobile browser settings you may be unable to access certain parts of Solo. Unless you have adjusted your mobile browser setting, our system will issue cookies when you direct your browser to Solo.

Log file information. Log file information is automatically reported by your mobile browser each time you make a request to Use Solo. When you Use Solo, we and our Service Providers may automatically record certain log file information, including your web request, IP address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on and through Solo, domain names, landing pages, pages viewed, and other such information. The information allows us to receive more accurate reporting and improve Solo.

Device identifiers. When you use a mobile device like a tablet or phone to Use Solo, we may access, collect, monitor, store on your device, and/or remotely store one or more “ device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may identify data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may deliver information to us or to our Service Providers about how you Use Solo and may help us and others (on our request) produce a report on such Use.

Some features of Solo may not function properly if use or availability of device identifiers is impaired or disabled. Among others we collect the following device identifiers:

  • User device ID.
  • Platform (iOS/Android).
  • Device OS version.
  • App version.
  • First request time.
  • Language.
  • Model.
  • Adevertisement ID.
  • Push token (optional).

Metadata. Metadata is a technical data that is associated with your data. For example, metadata may describe when and on which device your photo has been taken and how such photo is formatted. You may add or may have metadata added to your data. Please note that metadata associated with your data is deleted automatically with your data within 24 hours after we apply styles to them.

Registered Users. If you are a registered User, we may collect more Personal Data about you including the following:

  • Email.
  • Phone Number
  • User device ID (generated by our application).
  • First User authorization date and time.
  • Name
  • Gender

4. HOW WE USE COLLECTED INFORMATION

Your data. We do not use data you provide when you use Solo for any reason other than to provide the core functionalities of the application unless you have given us your explicit consent to use the data for a different purpose.

Please note that to identify the user connections based on your data we may upload such data to the cloud providers we use (Google Cloud Platform and Amazon Web Services), in which case, the data: (i) become available to us anonymously and (ii) are automatically deleted within 24 hours after being processed by Solo, unless you have given us your explicit consent to use the data for a different purpose.

Other information. We may use your information other than data for the following purposes:

  • To provide personalized content and information to you and others in relation to Solo, which could include online ads or other forms of marketing (including via email).
  • To present to you and others with Solo, its contents and any other information, products or services that you request from us.
  • To automatically update Solo on your device.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us in relation to Solo.
  • To provide you with support and to respond to your inquiries. If you share your Personal Data (including your name and contact information) to ask a question about Solo, we will use that Personal Data to investigate your concerns, respond to your inquiries and to monitor and improve our responses to your and other Users inquiries in relation to Solo.
  • To notify you about changes to Solo or any products or services we offer or provide through Solo, including by sending you technical notices, notices about your account/subscription, including expiration and renewal notices, updates, security alerts and support and administrative messages, which we may send through an in-app or a push notification (you may opt out of push notifications by changing the settings on your mobile device).
  • To diagnose or fix technology problems in relation to Solo.
  • To link or combine with information we get from others or (and) from you to help understand your needs and provide you with better services.
  • To monitor metrics such as total number of Users, traffic, and demographic patterns (including via Service Providers as specified in Section 6).
  • To provide, improve, test, and monitor the effectiveness of Solo.
  • To develop and test new products and features.
  • To fulfill any other purpose for which you provide it.
  • In any other way, we may describe in this Privacy Policy.
  • For any other purpose with your explicit consent.

We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or authorized by you in accordance with this Section 4 or collect any Personal Data that is not required for the mentioned purposes (“purpose limitation principle”).

For any new purpose of processing, we will ask for your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that your Personal Data is reliable for its intended use, accurate, complete and current. We also undertake to collect only such amount and types of your Personal Data that are strictly required for the purposes mentioned in this Section 4 (“ data minimization principle”).

5. YOUR RIGHTS

Access, modification, correction and erasure. You can send us an email at memedd@wldd.in to request access to, modification, correction, update, erasure or deletion of any Personal Data that you have provided to us and that we have about you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

  • Access to your Personal Data and data portability. You have a right to request information about whether we have any Personal Data about you, to access your Personal Data (including in a structured and portable form) that you have provided to us, when Using Solo and that we have about you. You can do this by contacting us.
  • Rectification of your Personal Data and restriction of processing. You are responsible for ensuring the accuracy of your Personal Data that you provide to us. Inaccurate information may affect your experience when Using Solo features and our ability to contact you as described in this Privacy Policy. If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data. You also have the right to demand restriction of processing of your Personal Data, if you contest the accuracy of the Personal Data which inaccuracy is verified by us.
  • Erasure of your Personal Data. If you believe that your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your Personal Data, you have the right to contact us and ask us to erase such Personal Data. Please be aware that erasing some Personal Data may affect your ability to use Solo.
  • Right to object processing or otherwise using your Personal Data. You can object to and stop us from processing or otherwise using your Personal Data by contacting us. Please be aware that our inability to process or otherwise use some of your Personal Data may affect your ability to Use Solo.
  • Notification requirements. We commit to notify you promptly and your data protection authority within the timeframe specified in applicable law (72 hours) about any Personal Data breaches in relation to you.
  • Notice about automated decision-making. We use automated decision-making tools (e.g. neural networks) that process your data in order to provide you better services through Solo.

Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage you in a dialogue to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.

We might also ask you to prove your identity (for example, by requesting an ID or other proof) in order for you to invoke the mentioned rights. This is made to ensure that no right of third parties are violated by your request, and the mentioned rights are exercised by an actual Personal Data subject or an authorized person.

Please note that we will grant your request within 30 days after receiving it, but it may take up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.

Opting Out of Promotional Emails

IF REQUIRED BY LAW, WE WILL ASK FOR YOUR CONSENT TO SEND YOU PROMOTIONAL AND MARKETING EMAILS. IF YOU WISH TO OPT OUT OF OUR PROMOTIONAL AND MARKETING EMAILS, YOU CAN OPT OUT FROM OUR PROMOTIONAL AND MARKETING EMAIL LIST BY USING ANY OF THE FOLLOWING METHODS:

  • by following the opt-out links in any marketing email sent to you; or
  • through Solo settings on your mobile device; or
  • by contacting us at any time using the contact details in How to Contact Us Section.
  • Contract. One reason we might use your Personal Data is because you formed a contract with us by accepting the Solo terms of use, and use of your Personal Data is necessary for the performance of the contract. For example, to enable you to access and use Solo or send you information that you have requested.
  • Legitimate interest. Another reason we might use your information is because we have a legitimate interest in doing so. For example, we need to use your Personal Data to operate, protect, improve and optimize Solo and your User experience, such as to perform analytics and conduct research.
  • Consent. In some cases we will ask for consent to use your Personal Data for specific purposes. If we do, we will make sure you can revoke your consent in Solo settings or by contacting us.
  • Legal obligation. We may be required to use your Personal Data to comply with the law, for example, when we need to take action to protect our Users.

6. SHARING OF COLLECTED INFORMATION

We may disclose aggregated information about our Users and information that does not identify any individual without any restriction. We may remove parts of data that can identify you and share anonymized data with any persons.

We do not rent or sell your Personal Data, including data, to any third parties outside the Company or its Affiliates (as defined below).

Parties with whom we may share your Personal Data. We do not share or transfer your data to third parties (with the exception of uploading the data to our cloud providers Google Cloud Platform and Amazon Web Services to provide online processing function and storing and deleting such data as described in this Privacy Policy).

We use only secure places of storage, such as Google Cloud Platform and Amazon Web Services. Google LLC and Amazon Web Services, Inc. are located in the United States of America. To learn about data protection practices of Google LLC please visit the following link. To learn about data protection practices of Amazon Web Services, Inc. please visit the following link. We may share your Personal Data as well as other collected information (including but not limited to information from cookies, log files, device identifiers and Usage data) with businesses that are legally part of the same group of companies that we are part of, including our subsidiaries, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve Solo (including by providing analytics). Such Affiliates are bound by the rules of this Privacy Policy.

We also may share your Personal Data and other collected information with third-party organizations such as contractors and service providers that we use to support our business and who are bound by confidentiality and data protection terms (consistent with this Privacy Policy) to keep your Personal Data confidential and use it only for the purposes for which we disclose it to them (and as directed and authorised by us) (“Service Providers”). 

Such Service Providers include (i) cloud providers Google Cloud Platform and Amazon Web Services, that we use to apply features of Solo to your data and to store and delete such data, as described in this Privacy Policy, (ii) third parties that may use your data collected by us in the ways described in this Privacy Policy and where legally required with your explicit consent, (iii) third-party analytics, as specified in this Privacy Policy, (iv) email delivery services and (v) professional advisors, such as lawyers, auditors and insurers, in the course of the professional services that they render to us.

What happens in the event of a change of control. If we sell or otherwise transfer part or the whole of the Company or our assets to another organization (e.g., in the course of a transaction like a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, liquidation), your Personal Data and any other collected information may be among the items sold or transferred. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

Responding to legal requests and preventing harm. We may access, preserve and share your information in response to a legal (like a search warrant, court order or subpoena), government or regulatory request if we have a good faith belief that the law requires us to do so. This may include responding to legal, government or regulatory requests from jurisdictions outside of the India where we have a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: (i) detect, prevent and address fraud and other illegal activity; (ii) protect ourselves, you and others, including as part of investigations; and (iii) prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

7. DATA SECURITY

We use reasonable and appropriate information security safeguards to help keep the collected information secure and to secure it from accidental loss and unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Solo or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for circumvention of security measures contained in Solo. Please understand that there is no ideal technology or measure to maintain 100% security. Among others, we utilize the following information security measures:

  • Pseudominization of certain categories of your Personal Data.
  • Encryption of your Personal Data in transit and in rest.
  • All collected information is stored on our secure servers behind firewalls.
  • Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of Solo. We impose strict liability on such employees for any disclosures, unauthorized accesses, alterations, destructions and misuses of your Personal Data.
  • Conducting periodical data protection impact assessments in order to ensure that the Company fully adheres to the principles of “privacy by design”, “ privacy by default” and others. We also commit to undertake privacy audit in case of the Company’s merger or takeover.

The safety and security of your information also depends on you. Your privacy settings may also be affected by changes the social media services, through which you may share your data, make to their services. We are not responsible for the functionality, privacy or security measures of any other organization.

Contacting us. You can provide your feedback or report a technical issue by using “Send Feedback” button in Solo settings. The email will be sent from your personal email to memedd@wldd.in, and the message will contain the following diagnostics information that will help us to resolve your issue/address your request:

  • Phone model.
  • Device OS version.
  • Platform (iOS/Android).
  • App version.
  • User device ID.
  • Language.
  • Remaining space.

This information is used to assess your feedback and/or identify the problem if you are reporting one and is NOT USED to identify Users individually.

Contacting you. By Using Solo you consent to receive electronic communications from us (e.g., by posting in-app notices in Solo, push notifications or emails). These communications may include notices about Solo (e.g., changes/updates to features of Solo and their scope, prices of in-app subscriptions, technical and security notices, updates to this Privacy Policy and Solo terms of use), Solo in-app subscriptions and marketing and promotional materials. 

8. DATA RETENTION

We retain your Personal Data for as long as we need it for the purposes for which it was obtained or until you ask us to delete it. We also may retain your Personal Data for a longer period of time on the basis of our legitimate interests, for example, as necessary to comply with our tax and legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Data, we may continue to retain and use aggregated or anonymous data previously collected that can no longer be used for personal identification.

9. CROSS-BORDER TRANSFERS

The Company is based in the India. Accordingly, your Personal Data may be transferred to and stored on servers in the India. Your Personal Data may be transferred to any country where Google Cloud Platform and Amazon Web Services have/use servers.

The data protection and privacy laws of the India may not be as comprehensive or offer the same protections as the laws in your country. For example, personal data transferred to the India may be subject to lawful access requests by legal authorities. You nevertheless consent to the transfer of your Personal Data to the India and other countries where the Company is located, or is providing products or services, or from where its Affiliates and Service Providers provide their products and services to the Company and its Affiliates.

10. CHILDREN’S PRIVACY

General age limitation. Solo is not intended for or directed at children under 13, and we do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to Use Solo. If you are under 13, do not: (i) Use or provide any information in Solo or through any of its features, or (ii) provide any information about yourself to us, including your name, address, telephone number or email address. In the event that we learn that we have collected or received any Personal Data from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us (for contact information, please, see How to Contact Us Section).

11. OTHER WEBSITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from Solo, including the information or content contained within them. Where we have a link to a website or service, linked to or from Solo, we encourage you to read the privacy policy stated on that website or service before providing information on or through it.

12. HOW TO CONTACT US.

General contact details. If you have any questions about this Privacy Policy or Solo, please contact us via email at memedd@wldd.in or our mailing address:

WLDD Private Limited

No.61, “Nalanda”, Opp. Basavanagudi Head Post Office

K R Road, Basavanagudi, Bangalore Karnataka 560004

Phone : 9886830664

13. CHANGES TO OUR PRIVACY POLICY

The Company may modify or update this Privacy Policy from time to time, so please review it periodically. The date this Privacy Policy was last revised is identified at the top of the page. Your continued Use of Solo after we make changes to this Privacy Policy is deemed to be acceptance by you of those changes, so please check the policy periodically for updates. In some cases, we may require you to expressly accept our new privacy policy in order to continue Using Solo (for example, if we expand types of Personal Data collected from you or introduce new purposes of collection and processing).