Getting to grips with ESG and other concepts in sustainable finance

Thank you for using the Shoal Platform. The Shoal Platform is provided to you by Shoal Limited (“Shoal” a company incorporated and registered in England and Wales under company registration number 13846154).

Your personal data is important to us. We are committed to maintaining the confidentiality, integrity, and security of all personal information you provide us, or we collect about you.

This privacy notice (“Notice”) outlines how we collect, manage, and store your personal data in compliance with applicable laws and regulations. This Privacy Notice should be read alongside all other terms and privacy policies that together make up the Agreement between you and Shoal.

It is your responsibility to remain up to date with this Privacy Policy and those of our Partners, with whom you directly interact through the Shoal App and who may provide services to you from time to time. Shoal and our Partner privacy policies, and their past versions, are available on the Shoal website, and within the Shoal App. Privacy Policies for parties whose account access is not directly integrated into the Shoal App (i.e. Partners that you are introduced to only through the Shoal App) are not retained by Shoal.

This Privacy Policy remains in place until such time that either you or Shoal terminates your Shoal Platform User Account and / or you no longer make use of the Platform, the Website or the Shoal App.

This Notice must be read alongside the Shoal Platform and general Shoal Services Terms and Conditions

Across this Notice, “we”, “our” and “us” refer to Shoal, and “you” and “your” refer to the User of the Savings Pots.

All capitalised words found in this Notice are defined in the Glossary of Terms, and their definition applies both to the singular and plural use.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data more generally, please contact the Shoal customer support team. 

Email: support@joinshoal.co.uk

Shoal App: Log in to your app, go to Settings by tapping (⚙️) on the top right of your home screen and send us your query through our Help Centre.

Post: Shoal Customer Support, 1 Basinghall Avenue, London EC2V 5DD, United Kingdom.

You also have the right to complain to the UK Information Commissioner’s Office (ICO) about the way in which we process your personal data.  You can contact the ICO at https://ico.org.uk/make-a-complaint/

1. What Personal Data may Shoal collect and hold

We may collect the following Personal Data from you when you use the Shoal Platform or engage with any of Shoal’s or our Partner’s Services.

We may also collect this data from any Third-Party Service Providers or Partner that we rely on for the provision of the Shoal Platform or our or our Partner Services to you.

• Identity Information – including name, gender, date of birth, official ID numbers, digital copy of official IDs (passport, driver’s licence or similar) and photo image.
• Contact Information – including current and past email addresses, current and past mobile phone number, current and past addresses.
• Employment Information – which may include salary level, employer name, employment position/title.
• Financial Information – including bank account details (account number and sort-code), balances and transaction information related to any of the Services you access through the Shoal Platform.
• Technical information – including geo-location, IP addresses, device tokens, and device type information.
• Profile Information – including your username, password, PIN, preferences, any product or feature survey responses you provide.

If you do not provide us with the Personal Data, we or our Partners need to provide you with the services requested through the Platform or for us or our Partners to meet our or their legal and regulatory obligations, we or our Partners may not be able to provide you with the products or services you have requested.

Where relevant, before engaging with any of the Partner Services available through the Shoal Platform, you will be prompted to accept their privacy policy. Additionally, by accepting the Partner’s privacy policy, you give Shoal permission to share any relevant information with the Partner to speed-up your service onboarding process. The information that Shoal will share with the Partner will be limited to need to know information only (e.g., your name, date of birth, country of residence, your address, and your current contact details).

2. How will Shoal use my personal data

We will only collect, use, and disclose your personal data for the purposes set out in this Notice or for purposes of which you have been notified and consented to at the time of sharing this information, or which are otherwise permitted under applicable laws and regulations.

We will not sell, rent, or give away personal data to third parties for commercial purposes without your consent.

We (including our Third-Party Service Providers and Partners) may collect, use, disclose and process your personal data for the below purposes:

• To fulfil any of the Shoal or our Partner Services in accordance with the terms you have signed up or registered for through the Platform (together “the Agreement”);
• To comply with our or our Partners’ legal or regulatory duties arising from or connected to services you have requested, including to perform Know-Your-Customer (KYC) obligations, complying with and monitoring of compliance with applicable laws and regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body;
• In line with voluntary codes and / or in compliance with internal policies (including that of our Partners and Third-Party Service Providers), contractual obligations (including between us and our partners and service providers) and good practice standards;
• Based on our legitimate interest, including:
  • for our internal analytical or statistical purposes or where it is necessary for the proper functioning of the Platform and Shoal’s ability to communicate with you and our customers,
  • in connection with any legal, regulatory and / or law enforcement proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising, or defending our legal rights; or
  • to provide you with relevant information you may need to continue to make use of those Services you use through the Shoal Platform already; and
• where you provide us with specific and informed consent, we will process your Personal Data to:
  • Register you for our newsletter and mailing list,
  • send you updates and offers relating to our existing and future product offering,
  • reserve your place in line to receive our future products,
  • gather your feedback on, and other information in relation to, the development of the Platform, and; 
  • invite you to participate in competitions and prize draws.

3. Shoal may disclose your personal data to:

• Our Partners and Third-Party Service Providers anywhere in the world, including any officer, employee, agent, or director of any such party and to provide the Platform and related Shoal or our Partner Services to you and for all parties to meet their legal or regulatory obligations.
• Our professional advisers and service providers to provide administrative, financial, legal, accounting, information technology, research, or other services.
• Anyone authorised by you, as specified by you or in any contract with you.
• Any person to whom disclosure is required or permitted under applicable laws and regulations.
• Anyone we consider necessary to provide services in connection with the Platform.

4. How Shoal keeps your data secure

Your personal data may be transferred to, or stored at, a location outside of the UK, which may not have the same or similar data protection laws as those in the UK.

We will take such steps as are necessary in accordance with applicable law to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under the UK data protection laws. The security of your personal data is important to us. We have technical and organisational security measures in place to safeguard your personal data.

When using external service providers, we require that they adhere to specific security standards mandated by us. We may do this through contractual provisions and/or oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.

Neither Shoal nor its Partners and Third-Party Service Providers – nor any other Party with whom Shoal has shared your information in accordance with this Privacy Policy – can guarantee that your Personal Data is safe from cyberattacks (such as hacking, spyware, and viruses) which Shoal, and any related Party, could not reasonably have been expected or able to prevent. Aligned to the Shoal Platform and General Shoal Services Terms and Conditions, our liability to you is limited may such a breach occur.

5. How long will Shoal or our Partner’s or Third-Party Service Providers keep your data for

We retain your personal data in line with our legal and regulatory obligations and our business and operational requirements. This means that in most cases we will hold your Personal Data for up to 7 years from the end of your relationship with us, that is from the day you cease from being a Platform customer, unsubscribe from our mailing list (if you are not a Platform customer also), or otherwise inform us that you no longer wish to receive communications from us.

Our Partners and Third-Party Service Providers may have different retention periods for Personal Data that they have collected about you, through us, or by other means (including from you directly). We refer you to these parties’ privacy policies and Terms & Conditions (when available), which you must accept before making use of these parties services through the Shoal Platform.

Where our Partners or Third-Party Service Providers are not the data controller but are the data processor only, they must and will remove any Personal Data they hold about you from their systems; either at termination of our agreement with them or no later than when Shoal’s retention period ends.

6. What are your rights relating your Personal Data

In those instances where legitimate interest does not apply or where you have specifically instructed us not to process your data for the purposes of marketing new products and services to you, we will not send you marketing material unless you have specifically asked us to do so.

When you have asked us to send you marketing material, you have the right to opt-out of receiving such material at any time by sending us an email with a request to unsubscribe you from the marketing list or by clicking the “unsubscribe” link, where available.

For the avoidance of doubt, any form of communication from Shoal which relates to the proper functioning, operations and security of the services that you have registered for or signed up to through the Shoal Platform are not considered marketing material but are considered operational. Operational messaging falls outside the definition of marketing materials and you cannot opt-out of these types of messages / notifications.

In accordance with the relevant regulations, you have other rights regarding our, our Partners’ or Third Parties’ processing of your personal data.

To make a request to access, correct, erase or restrict the use of, to exercise your right to data portability, or to object to the way in which we process, the Personal Data Shoal holds about you, or to make a request to withdraw any consent previously given, you can contact our team (see section 8 for contact details).

To make such a request for any Personal Data held by our Partners, who may provide services to you directly or through Shoal, please refer to their privacy policy, which you accepted at the time of entering into the agreement with them and as it may have changed from time to time.

Please refer to the UK Information Commissioner’s website (https://ico.org.uk/for-the-public) for further information on your rights.

7. Updates to this Notice

This Notice may be updated from time to time and amendments take effect from the date they are placed on this site or made available through the Shoal App. Current and past notices will be available on the Platform.

You are advised to visit the Shoal App or our Website regularly to check for any amendments. This Notice was last updated on the date indicated at the bottom of this policy.  

Glossary of Terms

Agreement means:

• These Shoal Platform Terms,
• Any of Shoal or our Partners’ product-specific Terms (as they may apply to you from time to time when accessing these services through the Shoal App),
• The Shoal Privacy Policy and,
• Any of our Partners’ privacy policies (as they may apply to you from time to time when making use of their services through the Shoal Platform).

Partner shall mean third-party partners of Shoal from whom Shoal may obtain certain services in relation to the Platform and/or the Shoal Services, including but not limited to financial institutions, credit bureaux, verification companies, information repositories and such other parties as deemed necessary by Shoal to provide the Shoal Services.

Party / Parties shall mean, in relation to Shoal, its representatives, agents, and any of their respective officers, directors, equity holders, employees, parent entities, subsidiaries, affiliated entities, representatives, agents and licensors. Parties also include Shoal’s Partners and Third-Party Service Providers.

Personal Data / Information means information collected from you or about you that could be used to identify you, as defined more comprehensively in the Shoal Privacy Policy. 

Platform means the Shoal App, and any other digital channels through which you can access Shoal and / or our Partner Services and products that Shoal may create or introduce to you from time to time.

Shoal / Shoal Limited means Shoal Limited, a private limited company registered in England and Wales under number 13846154 with registered and correspondence address at 1 Basinghall Avenue, London EC2V 5DD, United Kingdom

Shoal App shall mean the mobile application belonging to Shoal which is developed and designed to run on various mobile operating systems, for providing the Shoal Services.

Shoal Services shall mean the services provided by Shoal to Users via the Platform which may be added to and amended by Shoal from time to time.

Third-Party Service Providers shall mean Partners, service providers and such other parties appointed by Shoal to provide services to Shoal and to Users.

Website shall mean the domain www.joinshoal.co.uk.

Last updated: 16 August 2023